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Limiting Loans and Hardships to Single Vendor


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A non ERISA plan wants to stay within the non ERISA safe harbor parameters of FAB 2007-2. If the plan has multiple vendors and wants to limit loans and hardships to a single vendor by amending the plan document/loan policy, does this constitute employer discretion regarding plan design and violate the FAB?

If so, could the TPA or consultant or vendor make the request to modify the plan in order to avoid employer discretion?

Thanks for your thoughts!

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