How to correct a fiduciary breach?

[Richard Anderson]

A small employer sponsors a profit sharing plan. The owner is trustee. The owner is also the world's best investor. On a hot tip he used about 90% of the plan assets to purchase options. Lost about 60% of the plan assets. He wants to make up the losses to all of the participant's accounts, except for his own account.

Can he make restorative payments to the plan based on his own determination that a fiduciary breach has occurred?

If so, can the restorative payments be made to only non-key accounts?

Are the restorative payments deductible for the plan sponsor?

The DOL voluntary fiduciary correction program doesn't cover this; is there a program that would cover this, or does the fiduciary just wait for a DOL audit?