403(b) Loans

[Guest dms9999]

ERISA 403(b) Plan has several TIAA-CREF contracts used by participants. All elective 403(b) contributions up to 6% go to the RA account and the match contributions (match is 100% up to 6%) go to the RA account established for each participant. Amounts deferred above 6% go to a GSRA or SRA account.

Loans are not permitted from the RA account but are permitted from the GSRA account. How can this plan comply with the DOL requirement that the loan program be available on a reasonably equivalent basis to all participants and beneficiarires?

Thanks