ADP Failure and Catch-up COntributions

[perkinsran]

I'm very confused on when catch-up are applied to an ADP failure. Can someone confirm logic below that Catch-up is applied as the last step before refunds:

Owner A age 45 $80,000 defers 5% or $4,000

Owner B age 51 $150,000 defers 5% or $7,500

Plan only support 3% HCE deferral, so $4,600 in refunds is required and split $550 to Employee A and $4,050 to employee B. Since B is catch-up eligible in 2004, he gets a $1,050 refund. Is this correct?

[Bird]

That's what I get. In this case, you carry the calcs all the way to the refund per employee and then apply the catchup.