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What scenario will fall under the QPLO. 

  1. Plan is Terminated, Participants are Terminated On or After that Plan Term Date; Loans are Offset as part of plan action to close out the assets on the plan (within one year of part’s term date):  When participant defaults on the loan after termination but less than one year from termination  is it a QPLO? Can Defaulted loan be a QPLO? I though only active/current loan can be a QPLO.  


     2. Plan is Terminated but not Frozen; Participants are Active and able to Contribute and Make Payments on Loan:  If the participants are able to continue to make loan payments after           the plan has terminated, a resulting default will not be a QPLO because the participant had the ability to make payments but did not, is that correct? 




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