Does a QNEC trigger exemption from TH for SH plan?

[jkharvey]

Strange scenario. Employer really goofed and did not withhold from employee pay any elective deferrals for 2014. Participants did complete deferral election forms. The Employer, however, did go ahead and make a deposit of those deferral amounts. We have treated this as missed deferrals under the EPCRS Rev Proc. The amounts deposited are now treated as QNECS. Does this now trigger TH and eliminate the exemption so anyone who did not have a missed deferral and therefore, no qnec, now needs TH minimum? I believe it is "yes", but am hoping for an alternative.