oldman Posted July 18, 2013 Posted July 18, 2013 A plan has several loans that have been long since defaulted. Some participants have never made a payment. Needless to say the plan has been a bit lax in their administration of these with no direction for deem distributions. Would there be an issue if they deemed these loans now? What tax year should they use? Any other reg issues that come to mind?
ETA Consulting LLC Posted July 18, 2013 Posted July 18, 2013 Agreed. Use a VCP filing to identify the issue (loans that were never defaulted) and the solution (deem them in the current tax year). Good Luck! CPC, QPA, QKA, TGPC, ERPA
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