tpa on this particular account is new and was thinking this type of situation of family 'employees' may have happened in other cases. tpa does not as of yet have any actual full census data. intent on here was to get a general idea on how to approach what it all means in terms of plan qualification, correction, potential distribution. Initial plan is to advise plan sponsor to obtain and consult counsel with these questions.
The loan limit is at the time the loan is issued.
His account balance after that is irrelevant for existing loans. It only effects his ability to take new loans, if allowed.