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Plan has many participants on workman's comp which is paid by an outside party. Thus, they don't pay through their payroll system, and do not deduct loan payments. Should participants on workman's compensation be required to make loan payments assuming this is not considered a bonafide leave of absence since they are receiving pay? If they are receiving compensation from a third party via "workman's comp", is this still considered being paid, and thus they are required to continue to make payments just as an active participant (in other words, they LOA regs would not apply)?

I am looking for guidance as to if a participant out on LTD receiving workman's compensation should make payments or not in order to determine how to proceed with many delinquent loans that are well past the cure period.

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