Failed 2016 ADP Test and Top Heavy Contribution Not Made

[msmith]

I have a takeover plan (from a payroll company!) that never corrected the 2016 failed ADP Test and the Plan Sponsor was never told the Plan was top heavy. If correcting the 2016 Plan Year, under SCP, can the QNEC also be used to correct the top heavy minimum allocations (same as the current year use of QNEC to satisfy TH minimums)?

[ETA Consulting LLC]

I think so. Would help to verify against the EPCRS, but that QNEC should pull double duty in the same manner it would have had it been allocated within 12 months following year end.

Good Luck! 

[msmith]

Thank you, ETA. I could not find anything in 2016-51 about double duty for this purpose.