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Yeah, love these legislative acronyms, but still waiting for the Working Toward the Future Act - although a colleague said he thinks most could be called that.

a chance possibility is the Bill in Govt will pass (I believed it has already passed the House committee), and then you could create a SHNEC retroactive (After plan year end) at 4%. so if you have a plan doomed to big failure then there may still be hope. The Bill eliminates the safe harbor notice requirement, so without going back and looking at it, it might be in there to amend to a 3% SHNEC before the end of the year as well. my brain is crammed too full of useless stuff so I don't remember now) There is no such option for a match because of course, that depends on whether someone defers.

It cannot unless the plan has never allowed deferrals. If the plan is amending to add a deferral option then yes, safe harbor can be added at the same time. Otherwise NO. Safe harbor cannot be added mid -year (though some in the industry wish it could be).

I recall on a complete withdrawal that the actuary calculates the years of the partial withdrawal as well and then provides a credit for any prior partial withdrawal liability payments. I had a similar issue a number of years ago and I believe that is how it was done.

It has been a very long time since I did participant loan work but this was the catch back then. Many payroll systems it seems like the employer just tells the system how many payments of $x to take and unless someone shuts it off early in the case of prepayments being made too much is taken from someone's checks and goes into the 4k plan by mistake. I agree it is a pain but based on what you have shared I am not seeing the ability to say "no". Maybe someone more current on loans can give you ideas.