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qualified plan loan offset amendment - timing

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This got shifted a year, but my head may not be shifting it, so I think I've got dates that don't line up...

As I recall, this was originally effective sometime in 2019 in proposed regs that could be followed, and we expected that the amendment itself could be done before 12/31/20 but effective in 2019 - we drafted a whole bunch of them then (that we held awaiting for a document restatement package that we still can't prepare, but that isn't part of this issue other than to say that these amendments are drafted to have an effective date of 2019 but not signed).  Then there was a one-year extension, and it had a "soft opening" in August 20, 2020, but was really truly effective starting 1/1/21.  So now I presume the amendment has to be done before 12/31/21 (never mind the tri-cycle restatement for the moment).

Can the amendment still be effective for 2019?  Or is that off the table?  Thanks.


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