Refinancing Participant Loans

[Cobras59]

For participant loans that are being refinanced, can the maturity date go ever go past 5 years from the original loan?  https://www.law.cornell.edu/cfr/text/26/1.72(p)-1, 26 CFR Section1.72(p)-1 Q-20, has that if the replace loans satisfies Section 72(p)(2) and this section determined as if if the replacement loan consisted of two separate loans; to the extent the amount of the replacement loan exceeds the amount of t he replaced loan, a new loan is amortized in substantially level payments over a period not later than the last day of latest permissible term of the replacement loan.   So if a refinanced loan is less than the available amount is it treated as a new separate loan and has a maturity date from the refinanced loan date and not the date of the original replaced loan?  Q-10 makes it sounds like it can.  Is there any other clearer direction than Q-20?

[Gilmore]

If the participant's balance can support the combined amount of the new loan created by the refinance, plus the balance of the loan being refinanced, you can start a new 5 year term for the new loan. 

Here is a good article:  http://employeebenefitplanaudit.belfint.com/participant-loan-refinancing/