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Posted

IS there a place where I can pull a sample participant loan program. For example, a separate written loan program is required in addition to the Plan Document in a Plan I am working with. Can someone recommend a site where such a document can be located?

I found this one on reish.com. Any comments?

http://www.reish.com/publications/pdf/loan...rogpolicies.pdf

If the SPD describes the loan program, do we still need a separate written statement?

Looking at the 2002 ERISA Outline Book (page 14.10), it seems as though all of the information I would need is already included.

Austin Powers, CPA, QPA, ERPA

Posted

If I remember correctly, McKay-Hochman's prototype document has it written in the document. They also had a loan policy that could be modified depending on the client. Check with your document provider and maybe they can give you the same thing.

Posted

If separate from the plan (which yours is), I would think it becomes part of the "plan" and I would not want to have the SPD included in that characterization. Anyway, the SPD should be brief, while the loan program should be much more detailed and legalistic (is that a word?).

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