Missed PSP Contribution - plan previously terminated

[Good401(k)]

Interesting scenario, appreciate any insight:

Facts:

• 401(a) profit-sharing plan (ER contribution only) has 6/30 fiscal year end.  Plan terminated 6/30/2017.
• Participant balances were rolled or distributed by prior record-keeper by 12/29/2017
• March 2018, it was determined that the contribution for plan years ended 6/30/15, 16, 17 may have been understated due to an error in the definition of compensation used.

Questions:

• Generally - how does this get unscrambled?  The prior accounts have been closed, the prior plan has been terminated, however, prior participants may be eligible for additional contribution.
• Does the corrective contribution need to go through old plan record-keeper?  Can they participants receive the contribution via check?  If check - would this be considered cash distribution 
• Any looming deadlines for the contribution to be made?

Any and all thoughts welcomed.

[Madison71]

You can correct through EPCRS even though the plan is terminated 

[david rigby]

21 hours ago, Good401(k) said:

... the contribution for plan years ended 6/30/15, 16, 17 may have been understated...

Assuming you really mean "may", it might be prudent to eliminate any doubt first, then determine (at least approximately) how many $$ are understated.  Only then would you then initiate any correction procedure.

[Luke Bailey]

Questions for Madison71 to avoid having to pore over 2016-51:

1) Given the timing, do you think this qualifies for self-correction, or since the plan terminated does this have to go in as a VCP submission. I'm thinking self-correction, but don't recall if there is anything specifically addressing one way or the other in 2016-51.

2) Since the trust no longer exists, can the employer just write the checks to the employees and "deem" them to be from a qualified plan? I think the IRS will give you that as a correction in VCP, but issue makes me waiver on whether can be done by self-correction.

[Bob the Swimmer]

Luke makes a good point but depending on the severity of the error and the fact that a lot of time has passed since 2015 and the fact that every balance was affected, SCP may not be available and you may have to go VCP.