Failed ACP test correction needed but match not funded

We have a client who failed ACP test.  The one HCE is entitled to the match but then must receive the correction.  Issue is the match has not yet been funded and the correction is to be made by March 15.  This is his first year int he plan so he has no other match source funds. 

I should know this but I'm thinking the ADP correction is due March 15 but an ACP correction is not dye until the end of the following plan year.  We know about the vesting rule - refund the vested portion only and forfeit the unvested amount.

Thank you

Both refunds are due by 12/31.  You just avoid an excise tax by also beating 3/15.

Thanks

So even the ACP must be done by March 15 - that's is what I always believed but if it isn't funded - well not much can be done.  We tell non-safe harbor clients to get their data in fast. And if they don't then that's that.

Even though March 15th is the date to avoid excise tax, it really isn't.  Each recordkeeper has their own processing date to get returns processed by 3/15.  For example, ADP had a 3/1 deadline for failed testing to be processed by 3/15.  I wish everything was June 30th.