Missed Deferral Opportunity using forfeiture account

[JKW]

A plan needs to fund a missed deferral opportunity and earnings - can the forfeiture account be used for this?

[chc93]

According to a recent Sungard/Relius technical update, QNEC for failure to implement a salary deferral election or improper exclusion of a participant from salary deferrals do not have to satisfy the "QNEC" regulation (100% vested when contributed). So they say that forfeitures should be able to offset the QNEC.

http://www.relius.net/News/TechnicalUpdates.aspx?ID=998