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I have a small plan with basic SH Match and discretionary PS (New Comp/cross-tested). Using Corbel’s Volume Submitter doc. Adoption agreement specifies SH Match to be calculated on an annual basis. They prefund throughout the year (by depositing per pay period when they deposit deferrals). Obviously, true-up is required at year end to ensure the annual calculation is accurate... The two owners want to see a projection maxing out. The TPA who performed similar projections last year did not true-up the Owners’ SH Match before solving for max PS, rather, they amped up the PS without taking into account the SH Match true-up. I am trying to figure out why. Although the owners are HCEs, all participants must have the SH Ma calculated on an annual basis, correct? HCEs cannot just opt out of true up, can they? One might say that as long as the NHCEs receive the true up, what is the harm? I lean towards this thought, though: FOLLOW THE DOCUMENT. True up should be done for HCEs, too. But, maybe I’m missing something here..? I searched the board and found a posting from a few years ago that said a client of theirs was under IRS audit for this and was still negotiating sanctions (but no update followed that I could find). Does anyone know where I can find supporting documentation - one way or another - on this?