Refund of excess commissions paid

[pensionlife]

401(k) Plan was in pooled accounts prior to 2012. Funds transferred to individual accounts in 2012.

In 2015, trustee receives $11,000 check made out to the plan for excess commissions charged while the plan was invested in the pooled accounts.

My inclination is to allocate this money based on balances held as of 12/31/2014 as opposed to going back to the 12/31/2012 valuation to figure out who was in the plan at that time. This plan has a lot of turnover, therefore, the cost benefit to try to find the terminated participants as of 12/312012 is not worth it.

Has anyone been in a similar situation?

[QDROphile]

You might get something out of EBSA Field Assistance Bulletin 2006-1.