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Certainly is, although it's still 110% of current liability, which for this purpose was never updated for PPA, so you just need to be reasonable and consistent. For a CBP, it's not account balances.

IMO, if the receiving plan does not allow new loans but does allow loans to be rolled over, it still needs a loan policy and all of these details should be covered under that policy. I'd suggest that it be reamortized on the new payroll schedule and would not be overly concerned about a few days difference in the final payoff date.

Honoring the participant’s request to stop payroll deduction cannot possibly be considered a violation of any provision of ERISA or the Code. Not honoring the participant’s request may very well give rise to state law cause of action. Seems like any easy decision.

Some lawyers read ERISA Advisory Opinion 94-27A (July 14, 1994) to suggest some reasoning under which ERISA might preempt a State’s wage-payment law. https://www.dol.gov/agencies/ebsa/employers-and-advisers/guidance/advisory-opinions/1994-27a For preemption to apply, Federal law need not regulate the same subject or object as what the State law regulates. Under ERISA’s express preemption, ERISA’s titles I and IV supersede a State law “insofar as [the State law] may . . . relate to any [ERISA-governed] employee benefit plan[.]” ERISA § 514(a), 29 U.S.C. § 1144(a). Further, a participant-loan procedure’s or other governing document’s provisions about repayment of a participant loan might be a part of a plan’s ERISA § 402(b) funding policy. A lawyer rendering advice about whether a State’s wage-payment law is or isn’t preempted might consider ERISA § 514(b)(4): “Subsection (a) shall not apply to any generally applicable criminal law of a State.” (Before ERISA § 514(e), some lawyers interpreted § 514(b)(4) as undoing a preemption that otherwise might apply if the State’s law made it a crime to violate the State’s wage-payment law.) Relevant law’s several (and compound) ambiguities suggest an employer needs its lawyer’s advice. (If the plan’s administrator is a person distinct from the employer, it too might need its lawyer’s advice.) Consider that a too-hasty decision in either direction risks a breach or violation.

Agree with MP it's a state law issue and same result in Virginia. This is an issue where ERISA does not preempt state law because there's nothing in ERISA that requires plan loan repayments from wages or when any such voluntary withholdings can be revoked.

Or an HCE/exec who wanted to bring in a large loan at hire.....