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Plan sponsor discovered several people that were not auto-enrolled, dating back several years on some. Plan document specifically states "Effective for Plan Years beginning after the adoption of the 2010 Cumulative List (IRS Notice 2010-90) restatement, forfeitures cannot be used as Qualified Non-Elective Contributions, Qualified Matching Contributions, Elective Deferrals, or actual deferral percentage test safe harbor contributions (Code section 401(k)(12))", so we know that the QNEC cannot be funded with forfeitures. What about the earnings adjustment on each QNEC - could they use forfeitures for this?

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