thepensionmaven Posted May 15, 2020 Posted May 15, 2020 Unclear as to whether the Suspended Loan Repayment Provision would apply to a new loan taken out currently.
Mike Preston Posted May 15, 2020 Posted May 15, 2020 Almost all loan provisions are like AAMCO; each one is independent of the other. But, yes, they can apply to such a loan.
Luke Bailey Posted May 18, 2020 Posted May 18, 2020 On 5/15/2020 at 12:12 PM, thepensionmaven said: Unclear as to whether the Suspended Loan Repayment Provision would apply to a new loan taken out currently. thepensionmaven, you talking about the CARES Act suspension? Section 2202(b)(2)(A) says the suspension applies to "an outstanding loan (on or after the date of enactment of this Act)…." That's not ambiguous. A new loan taken out on or after the date of enactment is outstanding the second after it's made. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034
thepensionmaven Posted May 20, 2020 Author Posted May 20, 2020 That is the impression I got, never hurts to get second opinion.
Luke Bailey Posted May 20, 2020 Posted May 20, 2020 Yes. With ERISA and Code, you're never quite through answering questions. Still waiting for that simplification bill. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034
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