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If a person is employed by 2 seperate entities offering 403(b) plans (she has no ownership/control in either, nos is an HCE) and has negotiated nonelective employer contributions with both, is the 54,000 annual additions limit seperate for each plan or is it a combined limit?

Then you didn't go to the right sessions.

If you follow through the exemptions, and the other statutes referenced in the exemptions list above, you will find that included in the list of exemptions is the "federal" exemptions from bankruptcy estates (i.e. property that is not considered available to pay creditors in a bankruptcy). ONE of those exemptions is the "debtors" interest in a qualified retirement plan. By the way, the DOL's position is that retirement plan assets are NOT attachable under the MVRA. Not sure I want to get in between the DOJ and the DOL on this one, but I just confirmed the DOLs opinion (informally) this morning.

You need a PPA restatement.

Or the distribution fees which is a place I think one could really complain about. I have seen $100 distribution fees in 401(k) plans charged to the participant. That seems easier and cheaper to get then some loan processing fee on terms.

You really want to think through the practical issues before you change a plan to do this. How will this person pay the loan back? if by check do you have a system of tracking and controlling the checks so they aren't lost/stolen when received? What happens if the check bounces? How does this cash get transmitted to the trust? Do you really want to spend all this time and energy for a former employee? I have seen exactly one plan that did this and they valued their former employees. It was a very successful management consulting company. They treated their alumni very well becasue they often times became members of upper management of companies. This give this consulting company an "in" to generating new business. Otherwise I have never seen anyone think it is worth it.