ACP Correction after termination

[jpdrews]

A client has terminated their 403b plan and paid out all assets. The final 5500 has been filed as well. In reviewing the filings I noticed that an ACP failure from two years ago was not corrected properly...specifically the ACP excess was refunded, but the client never made the one-to-one QNEC contribution required for late ACP failure corrections under EPCRS self-correction procedures. Questions:

1) I believe the client is past the "cure period" for SCP under EPCRS. Given they started the correction during the cure period, but did not completed, would they be allowed to make the required one-to-one QNEC correction or do they need to go under VCP?

2) Can they even do the QNEC to a terminated plan where all assets have been paid out?

Also, the client would technically be in a new plan year had it remained open...not sure if that matters.

Thanks!