415 excess in pooled account

Have a client with a pooled 401k/PS plan.

One owner had same earned income for 2018 and 2019.  In 2018, they deposited the 415 max, let's say, $27,000 plus the full catch-up.

In 2019, because the K! was identical, they deposited the max 401k and same PS as 2018 amount in August 2020. 

So, because the 401(k) limit went up $500 and with the same comp, she is over the 415 limit by $500.

How does the 415 refund work when it's all deposited tot he trust after EOY?  Do I just pull only the $500?  I'm not gonna do a mid-term valuation for a $500 refund.

I don't think I can just forfeit $500 of PS since 401k is the first 415 correction.

If the money is deposited after year end and in a pooled account, it doesn't necessarily belong to anyone. Money is fungible. So the records of the plan need to be corrected and the deduction needs to be corrected, but the cash is a contribution for the following year.

Thanks, Bill.

I came to that conclusion after I posted this.  I just may credit the regular employee with the $500 so the deduction is intact.