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Loan Balance - Required Minimum Distribution


Guest Amy Harle

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Guest Amy Harle
Posted

How do you calculate and distribute a minimum distribution for a participant who has only an outstanding loan balance?

Would this involve a partial deemed distribution on the loan...reported on 1099 for 2001?

Posted

Considering that a loan can only be for a maximum of 50% of the vested interest in the plan, I'm assuming the remaining 50% has been distributed via the RMD's.

Interesting point. The RMD is still calculated on the participants balance, which would include the loan. I would say that since the participant is making payments on the loan, that those payment might accumulate too be enough to cover the RMD in December.

Other thoughts?

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Erik Read, APR CKC

Posted

Interesting question. First, I'd check the document to see if loans are even allowed with a repayment period extending beyond a certain age (65, for example) - most documents I've seen do this to avoid practical problems such as this one. If the document terms have been violated, they have other problems!

Assuming this is a valid loan under the terms of the document, I agree with ERead that the outstanding balance is still considered in the account balance. I see no alternative to reporting the required amount, (over and above the available cash) as a deemed distribution. But I haven't reread the deemed distribution rules to see if they address this specific situation. Through the haze of memory, I don't recall that they do...

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