ADP correction - then match calculation?

[WCC]

Plan uses a discretionary match formula based on the plan year. Plan fails ADP test and refunds have been processed. 

TPA calculated the match excluding the ADP refund amounts, therefore reducing the HCE's rate of match on their entire deferral. This seems odd to me so I questioned the TPA as to why the match is being calculated after reducing the total deferral by the refunded amount. They told me the match can be calculate either way (before refunds or after refunds). Is that accurate? The plan document does not specify before or after.

Thanks

[Tom Poje]

maybe you just didn't find it in the document. here is language from FT William

(i) Correction Methods. The Plan may, pursuant to applicable Treasury Regulations, do any of the following to avoid or

correct excess contributions and/or excess aggregate contributions: (1) provide for the use of any of the correction methods described

herein; (2) limit contributions in a manner designed to prevent excess contributions from being made; or (3) use a combination of

these methods.