Deemed Distribution - Good test question for the pension geeks!

[Brenda Wren]

Participant has 4 loans outstanding; all were taken for 5-year terms.  Vested account balance exceeds $100,000.  Current loan balance, rate and maturity date:  $8500 at 8% matures 4/30/28, $4000 at 8% matures 9/30/28, $4700 at 8% matures 5/15/28 and $20,000 at 6.75% matures 4/30/31.  Loans are consolidated at current rate of 6.75%, new balance of $37,200 with a new maturity date of 6/30/31.  Does this loan consolidation exceed the loan limits and if so, what is the amount of the deemed distribution?