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Many record keepers agree with your boss. As far as I know, the rule is that the 50% balance must be in the account on the day the loan is issued, not for the life of the loan.2 points
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VFCP Notice to Interested Persons
ERISA11 reacted to Flyboyjohn for a topic
I take the conservative position and provide it to all participants and beneficiaries. However, in late deposit situations my clients usually decide to file the 5330s rather than rile up the participants with the notice.1 point -
Are Loan Offsets Mandatory
hr for me reacted to RatherBeGolfing for a topic
The assets in the account are not actually security in that sense. The 50% comes in to play only for calculating and issuing the loan. The loan is considered adequately secured when issued, subsequent changes to the account balance does not change that. From the ERISA Outline Book / Chapter 71 point
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