A plan wants to terminate mid year and is a safe harbor matching 401(k) plan. The plan has always made deferrals and safe harbor match only. The plan is top-heavy and relies on the exemption from T-H status due to SH match.

Am I correct in the following
1. 30 day notice to employees is required to cancel the match.
2. The plan will be subject to ADP/ACP testing for the year of termination.
3. The sponsor will need to make top heavy minimum contributions for the year of termination (because the exemption no longer applies).

Is there an exception for terminating plans that I am missing where one or more of the above would not apply?

Thanks in advance for any thoughts.

1.401(k)-3(e)(4) Final plan year. --A plan that terminates during a plan year will not fail to satisfy the requirements of paragraph (e)(1) of this section merely because the final plan year is less than 12 months, provided that the plan satisfies the requirement of this section through the date of termination and either --

(i) The plan would satisfy the requirements of paragraph (g) of this section, treating the termination of the plan as a reduction or suspension of safe harbor matching contributions, other than the requirement that employees have a reasonable opportunity to change their cash or deferred elections and, if applicable, employee contribution elections; or

(ii) The plan termination is in connection with a transaction described in section 410(b)(6)(C) or the employer incurs a substantial business hardship comparable to a substantial business hardship described in section 412(d).