"For 2020, the owner received $150 above the match formula. We're being told that because it's less than $250, EPCRS allows the excess to remain in the account. In other words, the the plan sponsor does not need to forfeiture the excess amount.

Does the $150 remain in the account and then get used to offset the 2021 match? Or does the owner get the benefit of the excess contribution for 2020?

I'm trying to wrap my head around the fact that the owner would be receiving an allocation higher than the NHCEs. If the excess were used to offset the 2021 contribution I could understand leaving the money in the account. Needing to remember to track the excess as an advance for 2021 could be a nightmare."