Failure to follow plan loan policy - EPCRS?

[t.haley]

Plan loan policy (that is incorporated into the plan document by reference) provides that a participant that has defaulted on a loan in the past is not eligible to receive another plan loan. Several such participants were allowed to have another plan loan in violation of this policy over several plan years. Is this an error that can be corrected through EPCRS? Is it a "plan loan failure" to be reported and corrected on Schedule 9 to Appendix C? The loans that were granted met the other requirements of the loan policy and Section 72(p). The plan sponsor wants to retroactively amend the loan policy to remove the "no loan if previous default" provision.

[Atila]

Hello, Did you find a soluntion to your plan loan policy failure question? Did you retroactively amend the plan? Did you determine whether you were able to self-correct? Thanks!