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An investment provider received a rollover check and allocated it to the wrong plan and thus to the wrong participant. The lucky individual had no plan balance otherwise. After the rollover was allocated to their plan account, they took out a loan. Some repayments have been made on that loan. 1. The person whose money was actually rolled in to the plan needs to be made whole, probably by the investment provider? I assuming the paperwork was in order but just not properly handled on their end. 2. The person who got the funds, via the loan, needs to pay back the loaned amount to the investment provider, not to their plan account? 3. The investment provider needs to empty out the account from the wrong person so it can be used for the correct person's account? Or is this an excess loan that is taxable and still needs to be repaid - but how can it be repaid as a "loan" when there was no balance to actually loan out anyway? Other ideas? -
Under Revenue Procedure 2013-12, in Appendix B, Section 2.01(1)(b)(iv)(B)(1), it states "the contribution ... is allocated to the account balances of ..." Later in that same paragraph, three more times it states "to the account balance(s)" Under this One-to-One correction method, could a plan sponsor allocate the QNEC only to eligible NHCEs that have account balances (meaning the Eligible NHCEs with a zero account are excluded)?