Defaulted Prior Year Loans

[Guest lrusso]

I have run into a situation in which a plan has a number of defaulted loans (some defaults occurred 10 years ago and others within the past few years), but no action has ever been taken to report as deemed distributions or to offset. All involve participants who had filed bankruptcy and their files were set aside. New administrator is trying to deal with these files now. We went through VCP on some other issues recently & tried to get the IRS to bless a plan of correction, but they stayed away from the issue. I'd like any comment on correction. This is obviously a very messy situation.