approval of loans fiduciary or misisterial function?

[k man]

is the approval or denial of loans by a tpa in accordance with loan program created by the plan sponsor a ministerial or fiduciary function?

[QDROphile]

Fiduciary. Several determinations have to be made for each loan.

[Locust]

I would add that the fiduciary could set up a loan approval procedure so that it can be processed by a recordkeeper as a ministerial function. In other words, the fiduciary would direct that a loan be issued if the recordkeeper receives a complete application form that meets the conditions for the loan set up beforehand by the fiduciary. The recordkeeper is processing the loan, but the fiduciary through adoption of its loan procedures is approving the payment.