Distribution Code for Excess Roth Contributions after April 15

Hi,

Which distribution code should be used for the following distribution? The participant exceeded the 402(g) limit for the year and did not distribute the funds by April 15 of the following year. All of the contributions were with the same company, so the distribution must be processed even though it's after April 15. The contributions that the participant put in were Roth. Since the earnings on the excess should be taxable because it's made after April 15, would the Code be "P", "1", and "B", assuming the participant is under 59 1/2?

Thanks!

Vlad401(k), I think the entire distribution will be taxable, not just earnings. See Treas. reg. 1.402(g)-1(e)(8)(iv). I don't see anything in 2019-19 that says the rule is different where you have to do it under EPCRS because same employer plan(s).