Restoring Forfeiture

[Cathy from Chicago]

Plan year-end is 4/30. Plan is a MP which has been frozen since '99. Vesting is 100% after five years. Forfeitures are reallocated same as ER contribution.

Received a call from client today advising that wrong census data was given to us for plan year ending 4/30/00. Per their original data to us, a participant terminated during the plan year without completing enough hours, thereby forfeiting his account; however, the Company now realizes he did complete enough hours and his account needs to be restored. News every administrator loves hearing. Not. To make participant whole, my thought is to use any forfeitures from the 4/30/01 valuation (hasn't been done yet) and if sufficient to pay him amount he should have received 4/30/00, fine; if not, have the Company make a non-deductible contribution to make him whole. Am I on the right wavelength for this? Secondly, is he entitled to the exact amount due him in '00 or do I figure in earnings/losses up to a current date? Thank you for anticipated help.