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Treas Reg 1.401(a)(31)-1 A 16 states the following:

A plan will not fail to satisfy section 401(a)(31) merely because the plan does not permit a distributee to elect a direct rollover of an eligible rollover distribution in the form of a plan loan offset.

My questions is....If you do not have to offer a direct rollover option for a loan offset, do you have to meet the 402(f) notice requirements?

How are others handling this? Do you send a notice and give the participant 30 days before offsetting? (I realize you should give the participant a reasonable amount of time after termination to repay the loan, but I am wondering if you have to provide the notice as well)

Thanks!!

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