One of our clients has a 401(k) plan. During 2017, the employer created 2 new controlled group companies. All of the employees then became employees of one of the new companies. We were never informed of this and the 2 new companies were never added to the plan as participating employers. They continued to deposit deferrals for the employees. Do the deferrals have to be refunded? Or can this be corrected under EPCRS? Any other suggestions?