Can allocations of ESOP stock from an existing ESOP Trust be considered as "contributions" to meet the 401(k) safe harbor for matching contributions?

Allocations of stock representing current employer contributions to an ESOP may be used as 401(k) safe harbor contributions if all applicable requirements for the safe harbor are satisfied.

Eight years later, I am asking a similar question: Client (S-corp if that matters) maintains an ESOP and a separate 401(k). May the 3% non-elective safe harbor contribution be made to the ESOP in stock, or must it be made in cash?

Thanks for any cites.

Cash or stock (of equal value).

IRC section 4975(e)(7) .... an ESOP is designed to invest primarily in qualifying employer securities.