Semi-annual allocation periods

[John Feldt ERPA CPC QPA]

An calendar year ESOP plan has 2 valuations per year, June 30 and December 31.

The allocation condition is that you must be actively employed on the last day of the valuation period.

An employee who is active on June 30 gets a June 30 allocation, but if they quit December 15, they do not get an additional allocation for the 6-month period ending December 31.

The plan uses a definition of compensation that passes 414(s). The plan uses a pro-rata allocation method for each 6-month allocation period based on compensation paid during that 6-month period.

Assume all 3 are true:

1. some employees get no allocations for the June 30 period because they left before June 30, and
   
2. some other employees get allocations only for their compensation paid through June 30th because they left before the end of the plan year but after June 30, and
   
3. some other employees get allocations based on full year pay because they were active on December 31.
   

Based on the assumptions listed, does this plan design require 401(a)(4) testing?