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I will keep beating this horse until it gives. Look at Notice 2005-92. It's not CARES Act guidance, but interprets the exact same statutory language in Section 103 of KETRA. Footnote 3, on page 14, reads: The Department of Labor has advised the Department of the Treasury and the Service that it will not treat any person as having violated the provisions of Title I of the Employee Retirement Income Security Act (ERISA), including the adequate security and reasonably equivalent basis requirements in ERISA section 408(b)(1) and 29 CFR 2550.408b-1, solely because the person made a plan loan to a qualified individual in compliance with KETRA section 103, Code § 72(p), and the provisions of this notice. I can't imagine the DOL now reversing course and asserting an ERISA violation based on a lack of adequate security, especially where doing so would render the statute's explicit loan increase illegal for anyone with a vested balance below $100,000.