Correction of SAR grant below FMV

[erisageek1978]

Plan granted SARs with exercise price below FMV.  Grant was in 2020, vested in 2021, 2022, and 2023.  No rights have been exercised.  Notice 2008-113 provides for correction only if correction is made in year of grant or by end of year following year of grant.  If no rights have been exercised, is it possible to still use 2008-113?

Also, now that we're in 409A land, what if the SAR grant satisfies all the requirements of 409A, meaning (1) specifies number of SARs granted (2) specifies exercise period (5 years from vesting date) (3) specifies exercise price.  Or, is this not sufficient since there is no specific exercise date, only an exercise period - 5 years from vesting.

Do we still have income at vesting? Or is this ok if otherwise satisfies section 409A requirements?