In-Service Distribution Failure

[Guest ERISAbeing]

Can anyone provide guidance on the correction prodedure for in-service distribution failures in a multiemployer plan?

I took a look at EPCRS and did not find a correction method provided for in-service distribution failures. My thoughts were to model a correction method after the correction method provided for hardship withdrawal failures (i.e., retroactively amend the plan to provide for the in-service distributions that were made available and then submit the amendment to the Service during the Plan's restatement cycle). Any guidance, any thoughts? Thanks in advance.

[401_4_ever]

I would also think about treating it as an overpayment under EPCRS.