Potential big difference for securities law compliance. If anyone cares. Document providers and TPAs typically don’t care. One wonders if the SEC or state enforcers care. Which is why you are wondering WTF this post is about.
If she stopped loan payments, then the loan is in default and a deemed distribution has already occurred, or will as soon as the cure period expires.
Technically, even after default, the loan obligation still exists. Repayments would create after-tax basis in the plan.
Terminating the plan creates a distributable event and then a loan offset occurs, which is a real (as opposed to a deemed) distribution.
In the Who Must File section:
Sponsors and administrators of government, church, and other plans that are not subject to the vesting standards of section 203 of ERISA (including plans that cover only owners and their spouses or cover only partners and their spouses) may elect to file Form 8955-SSA voluntarily. See the instructions for Part I, line A.