Could someone please help me understand the interplay between Code sections 401(a)(14) and 409(o)? My understanding is that 409(o) is an acceleration provision. Therefore, the general rule is that distributions must commence according to the provisions of 401(a)(14) UNLESS the participant ELECTS to accelerate distributions under 409(o). Is this correct? This would mean that a plan must distribute under 401(a)(14) even if the exempt loan has not been repaid in full?

Also, does 409(o) apply to S Corp ESOPs? I read somewhere that it does not, but there was no cite to the applicable authority for that statement.