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Are there any grounds to have a participant's deemed distribution within a 401(k) plan reversed? Are there any reg's that might list certain criteria that must be met? The loans deemed status occurred in 2017, if the record keeper already submitted the 1099-R is there a precedence for reversing it? Lastly, if there are grounds for reversal is it required that the process go through VCP? Your help is appreciated.
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This may be a dumb question, but I can't find a definitive answer on this in primary sources. If a loan has been treated as a deemed distribution (because of missed payments) and the 1099-R issued, can the participant make repayments on the loan beyond the 5-year maximum repayment period? It seems to me that this would be fine because the consequence of violating the maximum repayment period requirement is a deemed distribution, which has already occurred. So, after the deemed distribution, repayments beyond the 5-year period have no consequence. Does that seem right? The only example given in the regulations involves repayments within the 5-year period, so it doesn't really address this question. Any thoughts are appreciated.
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