VFCP for missed match/lost earnings?

[IhrtERISA]

Plan Sponsor applied an incorrect match % to certain employees for a 3 year period (in addition to failing ADP/ACP). All employee defferrals were prcessed timely and properly. Correction for the incorrect matching % is being done via VCP.

Would this also require a VFCP filing?

My take would be yes, since a prohibited transaction occured as a result of the incorrect match (and not corrected with the year) and for the lost earnings.

However, I do not see any applicable boxes on the VFCP model application.

Any suggestions?

[jpod]

I can't imagine a scenario or theory that would make a missed match a PT.