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Posted

The plan sponsor has two plans, a money purchase plan & a 401K plan. The employee is a participant in both plans. Each plan allows for loans and the limit of each plan is one loan at a time.

I understand that the $50,000 limit applies to both plans being treated as a single plan. Participant can only take a loan of $50,000 combined from both plans (not $50,000 from each of the two plans totaling $100,000).

Since each plan only allows for one loan at a time, would both plans be treated as a single plan limiting the number of loans to one total from both plans?

Posted

No; a loan may be received from each plan. The regulations do not provide that one plan's loan provisions (i.e. one loan at a time) applies to all plans. Therefore, each plan has its own provisions allowing for one loan.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

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