Lunch Lady

In interpreting the plan document, I would add that most ambiguities should be resolved in favor of the participant rather than the plan.

I think the plan has to act prudently like any other lender and make sure the borrower has the ability to repay the funds. For example, if the participant is unemployed, who would loan money without a ready stream of funds for repayment? I think this is a fiduciary issue. I have seen plans that permit it.

We filed a VCP for late RMDs in May. Case has not been assigned. Waiver of excise tax requested but what do you recommend we tell the distributee regarding his tax return due April 15? Doubtful we will have an answer by then. Considering giving him a letter to attach to his return.