Late Employer Contributions under VCP

[Guest medinael]

A plan operated as a safe harbor plan with a basic match in 2001, but the Plan Sponsor never made the safe harbor matching contribution. Plan Sponsor corrected under VCP and made the safe harbor matching contribution with earnings in 2007. Plan was frozen in 2006. Due to the freeze, there were no other contributions to the Plan in 2007 except the late safe harbor contribution. Plan Sponsor is now terminating Plan. Does the Plan sponsor need to perform 410(b) coverage test for 2007 or are the late employer contributions considered PY 2001 or 2002 contributions? The 2001 SH match normally would have been made in 2002 by the tax return deadline.