True-up / Benefits Rights and Features

[jsample]

An employer funds their discretionary match per pay period.  They also calculate a true-up at year end.  In order to receive the true-up, if any, the employee must be employed on the last day of the plan year.

Do I need to run Benefits Rights and Features on the true-up provision, or does the ACP testing suffice?

[jsample]

Answering my own question, the plan could end up having a matching rate for HCEs that is greater than the match for NHCEs, if a NHCE needed a true-up but terminated employment during the year.  I believe I would need to test under BRF.

 

[CuseFan]

agreed