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Rephrasing what I said earlier, "'"substantially level payments' made at least quarterly" is not the same thing as "substantially level quarterly payments." I think it's ok whether it is done over 4 years or 5 years, as long as the 5 year payments are scheduled to be done before the fifth anniversary. But good grief, why would anyone want to complicate this so? If it's a cash flow problem for the first payment or two, just schedule it normally but let them be 'late" (but not so late that the loan defaults).

https://www.erisapracticecenter.com/2018/01/annual-irs-revenue-procedure-includes-surprising-change-to-user-fees/ They got rid of the reduced VCP filing fees for stupid things like RMD's and loan defaults. Schedule of User Fees for VCP submissions, is revised to change the user fees to: $1,500 for plans with assets of $500,000 or less; $3,000 for plans with assets of over $500,000 to $10,000,000; and $3,500 for plans with assets of over $10,000,000. (4) All other reduced or alternative fees previously set forth in Appendix A, .09, no longer apply. so the small business which is likely to have loan failures and missed RMD's pays $1,500 or $3,000. Plans over 10 Million pay just $3,500. What a nice thing for the mega corporations. What an awful decision. I hate to be political but I swear the most important thing for this administration feels like undoing as much as possible from the prior administration.

Would you expect anything else from this administration?

Yup. We are starting to see them more and more - especially out of California. AND - they are directed to us as a service provider to the plan - and not to the plan itself (and I would argue that that is smart - there is some doubt as to whether a court can enjoin a plan except through a DRO. That raises an interesting question - if the plan fiduciaries DIRECT that a distribution take place (and they aren't restrained) but we can't do it, what happens (other than we get fired...)?