Forfeitures from Merged Plan

[52626]

On 1/1/2023 Company B merged into Company A's 401(k) Plan ( controlled group).

Prior to the merger Company B had a match tied to a vesting schedule.

Company A maintains a Safe Harbor 401(k). 

At the time of the merger there were  funds in  Company B's forfeiture account.  Company A needs to fund a  QNEC and Match for participants. Any issue with using the forfeitures that came from Company B to fund this contribution.

Once the plans merged, there is no distinction as to where which company generated the forfeiture, correct?   A forfeiture is a forfeiture and can be used to offset, SH match, pay admin expenses, or used to fund QNEC and missed match

[Nate S]

As long as the forfeiture amount in question was a current amount, meaning it had been generated during the 2022 Plan year, go ahead.  If it is monies that have been hanging around and should have been used in a prior year, I would allocate it to B participants in conjunction with the merger's preservation of benefits.