does a new co joining a MEP get the auto-enrollment 3 year grace period?

I've got a pre-enactment MEP (established years ago).  New Company G started up in 2024, wants to join the MEP effective 1/1/25.  They have 15 employees.  It seems like we get to use the 3-year grace period here for G and they don't have to start automatic enrollment until sometime in 2027 (or 1/1/28?).  Am I interpreting this correctly?  Or at least reasonably?  Putting aside the wisdom of doing it from the start for the moment...

“In the case of a plan maintained by more than 1 employer, subparagraphs [414A(c)(4)](A) [excepting an employer in existence for less than three years] and [414A(c)(4)](B) [excepting an employer until after it “normally employed more than 10 employees”] shall be applied separately with respect to each such employer.”

Internal Revenue Code of 1986 (26 U.S.C.) § 414A(c)(4)(C) http://uscode.house.gov/view.xhtml?req=(title:26 section:414A edition:prelim) OR (granuleid:USC-prelim-title26-section414A)&f=treesort&edition=prelim&num=0&jumpTo=true.