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A company inadvertently instructed its DB plan trustee to pay an invoice that related to its DC plan. Upon realizing the mistake, the company repaid the amount to the DB plan (it has not yet calculated or repaid any interest factor). This seems like a prohibited extension of credit from the DB plan to the company. Can (or should) this be submitted under the VFCP as a "loan at below-market interest rate to a party in interest"?

  • 2 weeks later...

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