ECRS "small benefits"

[t.haley]

EPRCS Section 6.02(5)(b) states that if a corrective distribution is less than $75 the plan sponsor is not required to make the corrective distribution if the cost to make the distribution exceeds the distribution amount.  This section goes on to state that it does not apply to corrective contributions "with respect to a participant with an account under the plan."  Can I apply this "de minimus" rule in the following situation: employee is improperly excluded from auto enrollment in plan with 2% contribution but the mistake is discovered after employee has terminated and therefore does not have an "account under the plan" (assuming the amount of the QNEC is less than $75)?  EPCRS requires a corrective contribution (100% vested QNEC plus earnings) which should be distributed to the employee ("corrective distribution"?).