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So I just heard from the enrollment folks at the IRS that they will not grant any CE towards my ERPA renewal, for studying for (and passing) at least one Enrolled Actuary exam during my 2019-2021 enrollment window. Guess I've got to download some recorded sessions this month. Grrrrr...... How is this not legitimate continuing education? What, it's not a "CE program" with an IRS-issued certificate? (If there weren't going to be a delay between my ERPA expiring and being able to apply to the JBEA, I'd just abandon the ERPA credential. EAs get higher ability to represent taxpayers than ERPAs.)

The retirement plan software that I've been exposed to over my career (ASC, Relius, Datair, FTW), do a decent job of creating an amortization schedule and setting up a loan. But they are not designed like bank loan software. So changes are incredibly clunky at best. It's also very difficult to get the TPA admin software and a recordkeeper's software to agree to $ with a single loan that never changes. So, any refinance is very manual, fraught with probable errors and guaranteed to be a revenue loser to the TPA.

The regs allow extending the length of the loan beyond the original 5 year period if certain conditions are met. There are two options, yuck and double yuck. See 1.72(p)-1 Q&A 20 (a)(2). ASC's cycle 3 401(k) document includes an optional loan program that allows restrictions on loan renegotiations, provided the ability to renegotiate is available on a non-discriminatory basis. It also has an optional to not allow renegotiation.

Sure. It's just a loan. Depending on the bank's involvement (if any) in the loan's origination, and other factors, you could have prohibited transaction of fiduciary issues.