"110% Rule" Failure - Failure to restrict distribution to/obtain secured repayment obligation from restricted employee

Ongoing DB plan fails to limit distribution to restricted employee (HCE benefitting under plan) as per 1.401(a)(4)-5(b)(1) and fails to obtain secured repayment obligation per Rev. Rule. 92-76. Occurred during 2019 plan year. As to correcting this, it seems like the choices are either contribute so that assets equal/exceed 110% of current liabilities, and/or obtain a properly secured repayment arrangement. But these would not reach back to when the violation occurred -- they'd be done currently (of course, no harm in last 20 months so no foul?). Any thoughts? Also, probably needs to be VCP -- Thoughts are appreciated.

Wondering if you ever got feedback on this, as I have the same question.

Just to throw the idea out there - I'd like to find out how such a scenario aligns with the new benefit overpayment rules of secure2.

(Yeah I know, I could do a bunch of reading, but maybe someone else already knows for sure.)

My thinking is that this really isn't an "overpayment," since the participant is entitled to the accrued benefit, just not in the lump sum form at the time they wanted it. Since the 110% test is part of the 401(a)(4) regs, this is a non-discrimination failure. I'm thinking the best way to correct this is to try to comply with 92-76 retroactively. Putting the money in escrow probably wouldn't work after the distribution is made, but securing a letter of credit to repay if needed might work. What do you think?