How to correct loan violation for owner-employee

[Guest phil2004]

In this case, the owner-employee took out a loan (less than two years ago) in violation of a loan policy provision that the term of the loan cannot exceed the lesser of 30 years or the number of years prior to Normal Retirement Age. Age discrimination issues aside, this is clearly an operational violation. Because this involves an owner (presumably a plan fiduciary), should the VFC program be used and a no action letter sought? On the other hand, can we simply use SCP and self-correct?