Timing to fully vest termed EE's non-vested balances?

[Guest KGriffith]

I have an ESOP that froze contributions and fully vested participants on 9/30/99. The Plan states that forfeitures occur following a 1-year BIS. At the time the Plan was frozen, the ER did not restore forfeitures for those participants who had not received a distribution from the Plan, were partially vested, but had forfeited their non-vested balance prior to having a 5-year BIS. On 9/30/01, the Plan terminated.

The question is whether or not forfeitures need to be restored for those participants who never received a distribution from the Plan, but whose non-vested balance was forfeited prior to their having a 5-year BIS, as of the date of freeze?

Thanks