In-service distribution of elective deferrals before age 59-1/2

[Guest jcm0]

We have a plan that's been distributing deferrals to participants while employed but under age 59-1/2. This has happened infrequently enough that we would like to correct the operational failure under SCP. As part of the correction process, we would attempt to recover the distributions from the affected employees. In the very likely event that these employees will refuse to return the distributions, would SCP still be an appropriate correction? Would we be better off going through VCO or VCP?