Rev Proc 2015-28 and Terminated Employees

[Gruegen]

A participant should have been automatically enrolled at 3% effective January 1, 2015, but due to an error, was not automatically enrolled. The participant terminated employment on June 30, 2015 with the participant never having any 401(k) deductions. The error is discovered in November, 2015.

Is the error eligible for the new "safe harbor correction method for failures related to automatic contribution features in 401(k) plans" as added by Revenue Procedure 2015-28 such that there is no corrective contribution for the missed deferral opportunity?

Or because "correct deferrals" never began, is the plan required to correct under the Elective Deferral failure that requires the 50% missed deferral opportunity?

I would think that the fact that the participant terminated employment should not disqualify the plan from fixing under the new (more favorable) guidance of Revenue Procedure 2015-28, but I am not sure that the guidance addresses this type of situation.