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Posted

It is my understanding, the loan gets offset when the participant has a distributable event.  Therefore, if the plan allows for distributions at age 59 1/2, and the participant is still employed. the loan will offset when the participant turns 59 1/2.

But what happens if the 59 1/2 withdrawals are restricted to deferrals only and the loan was taken from deferrals and match?  For example, a $10,000 loan was taken: $6,000 from deferral and $4,000 from match.  $5,000 was paid back, so his loan balance is $3,000 in deferral and $2,000 match.

Loan defaults, deemed distribution processed.  Participant still employed, and turns 59 1/2 on May 1.  Plan allows for distributions of deferrals only at age 59 1/2.  So he has a distributable event (for deferrals) on May 1.  Does $3,000 get offset?  All $5,000?  None?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

I guess technically only the deferral part would be offset but I think for sanity I would adjust some of the balance from match to deferrals, if that can be done.  Otherwise wait to offset the whole thing when match is available (or just offset the whole thing now, which is incorrect but really the sanest thing to do...yeah that).

Ed Snyder

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