top heavy - can it be self corrected?

[k man]

i dont see any reason why not but thought i would put this out there. approximately 10% of the participants did not receive top heavy mins for two plan years. dollar amounts are relatively small - 11,000 and 15,000 for each year respectively. i would like to self correct rather than use vcp. any thoughts.

[Bird]

Yes, it's in EPCRS. The last day of the correction period is the last day of the second plan year following the plan year in which the failure occurred. So you can still fix 2003 in 2005 (you have to add interest).