Plan Loans

[Guest Ken C]

While starting conversion of a takeover plan have discovered prior loans did not follow loan provisions of the document, ie multiple loans were made under the document specified minimum of $1,000. In addition all loans were made at a 6% interest rate.

This is a large plan and will be audited. The last seminar I attended regarding EPCRS and VCP seemed to suggest there are no correction methods for loans.

Any cites or suggestions would be appreciated.

[Belgarath]

Although I'm not aware of a specific pre-approved fix for this in Rev. Proc. 2006-27, that doesn't necessarily mean that it is ineligible for correction. Depending upon facts and circumstances, I think this could still be submitted under VCP, or at worst as a "John Doe" submission.