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I am assuming the amendment was not written to answer these questions which it should have been done. If the amendment doesn't answer this question then all plans give the Plan Administrator the power to make reasonable interpretations of the plan that don't discriminate. The PA needs to use that power to answer these questions. To me I don't see how you don't grandfather the existing loans. It might even be a protected benefit since it exists. The next two I can make a case for either one and the PA would seem reasonable. What I mostly see is you can't refinance in either case. You might have 2 loans but any change needs to result in 1 loan after the change. Likewise in 3 any change needs to result in zero loans.

Not having kept adequate records itself, sorry to say but the first place for the plan to complain is while standing in front of a mirror! Is there a reason why the former TPA is not being cooperative?