Prior to sponsor paying QNEC to plan, sponsor files bankruptcy. Owners of sponsor are plan participants and also the plan fiduciary. Other than pursuing collection of the QNEC in the bankruptcy or suit against plan fiduciary, is there any (simple) procedure or ruling allowing/mandating transfer of the QNEC amount from the owner/fiduciary/HCE plan account to the NHCE accounts? Thanks for any suggestions.

Other than an authorized fiduciary placing a proof of claim in the bankruptcy filing, NO!

halka:

What is your theory that the employer was obligated to contribute the QNEC? I've never seen a plan that required that the employer contribute QNECs.

Was QNEC required in document? Was it a safe-harbor qnec with advance notification?

If the QNEC was not made, then you have general ADP/ACP test. If it failed, then you have remedies to pursue, including refunds, disqualification, etc.

My advice: start taking with benefits administrator about consequences of no qnec.