IMHO, your OP is about the use of forfeitures, and it requires that if there are unpaid plan expenses, forfeitures must be used to pay those plan expenses first, before you can allocate any forfeiture amount to participants' accounts.
They had the same interpretation (I submitted to Corbel and here at the same time). I too though was left longing for that sentence in the Basic Plan Document that made this clear-cut. Their interpretation seemed to be focusesd on the fact that forfeitures could/should be used towards unpaid expenses. Because the recordkeeping was paid when charged/incurred, you did not have to use forfeitures first.