401a26 prior benefit structure testing - one more question

[Jakyasar]

Have been reading and researching on this and getting very confused and losing my mind. Hopefully some has an insight.

Never did this before and need to (CB plan - PBGC covered, top heavy and NOT underfunded). My system does not to prior benefit structure testing so need to do all manually (confirmed with the vendor).

Plan effective 1/1/2021 and combined with a DC plan.

Plan is hard frozen early 2025 with no one accruing a benefit (except one owner getting AE increase as past NRA). I do not see any relief under SECURE 2.0 for this.

I did the prior benefit structure testing and failed by 1 so need to 11-g.

The confusion (or not understanding) I am having is that the 11-g is for a current year increase so how do I include this person into a testing that is performed at beginning of year? This person will have 1 additional year of accrual/participation versus others.

I am sure I am not making sense here or totally missing something.

Thank you for your time and any insight you can provide.