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NO... No..... no.... no.... no......

Is there an echo in here?

This is our understanding of it: Because of the extensions provided by the IRS, the deadline to make loan repayments due on or after April 1 (without running afoul of the deemed distribution rules), is extended to July 15. This applies to all loans, not just loans to Qualified Individuals which can enjoy a longer suspension period under the CARES Act. With maximum use of regulatory cure period provisions, a participant can make up any missed payments by December 31. For example, if a “non-qualified individual” stops making payments any time during the period of 4/1/2020 through 7/15/2020, it’s treated as if the payments stopped during Q3 2020, thus making the end of the cure period 12/31/2020.

Correct. And the relevant language in Notice 2018-58 can be found in Section 8.1 (page 40)

(Apparently) it was the reference to Notice 2018-58. (I'm not sayin' I knew it, but I found that explanation.)

The one year rule has never existed in a defined benefit plan. If you read the Code carefully it actually goes much further: effectively a "forever" year rule. The IRS came out with a non-sensical TAM that lowered "forever" to the five year rule, but I won't look this particular gift horse in the mouth. Loosely translated, they reasoned that if a five year rule applies to defined contribution plans it is reasonable for the IRS to apply the five year rule to defined benefit plans, too. But the ruling says that plan provisions can work in favor of the "forever" rule if they chose, so the advice to check with plan counsel is wise. I'll try to attach the TAM. I got a copy of the unpublished TAM from a lawyer at the PBGC about 10 years ago who said that until the TAM was issued the PBGC was bound by the Code (the "forever" rule). I think you will find this in the Code structured as the forever rule is the default, but In the case of a defined contribution plan the five year rule applies. So, DB plans are left with the forever rule. Or at least they were until the TAM. TAM - Partially vested P_1.pdf

"The Universe is under no obligation to make sense to you". Neil deGrasse Tyson The same principle applies to Congress, statutes, and regulations.

Ah, so that's why they run out of money. ?