Distribution made in the abscense of a distributable event

If a plan distributed assets to a participant that wasn't 100% vested in a situation that wasn't a distributable event, is anyone on the hook for paying back the plan? They way I'm reading EPCRS, it seems that if the employee was still employed when it happened, no corrective contribution would need to be made to the plan. What if 6 months later this employee terminated? Would that trigger a repayment of the forfeited amounts if the employee never paid the plan back?

It seems clear the plan needs to be made whole for the amount that would have been forfeited.    EPCRS is only speaking to if it was paid in error for the lack of a distributable event.  In such a case no one is "hurt" as the person only got their money- just early.

In this case anyone that would get a forfeiture allocation would be hurt if the forfeitures are re-allocated. 

If the forfeitures reduce then the money is being paid to the plan regardless as less forfeitures means large contributions.   I would still go through the process to cover the plan and just in case no contribution is made- at which time it becomes like the forfeiture re-allocated fact pattern.