QSLP's

Just general discussion re the reality of actual administration. Seems to me that if an employer chooses to offer this, requiring employee self-certification of the 5 required certification elements, annually, would be the way to go. Is there any particular advantage to going with the registering the loan with the employer, or registering with a third party service provider?

I'm also wondering about the realities of what happens when the certification is incorrect, or the loan itself doesn't qualify as a QEL in spite of the certification. According to Q.E-4 of Notice 2024-63, if the certification turns out to be incorrect, the match does not need to be corrected. So does this really amount to a "get out of jail free" for the employer, or are there other ramifications?

The initial determination of whether there is even a Qualified Education Loan (QEL) in the first place can be fairly complex, and I'm not sold on the ability of most participants to accurately make this determination. And I sure as heck don't want to deal with it at the TPA level.

Are you seeing a lot of demand for it? We've only had a few inquiries, but it is coming...

Any discussion is welcomed. 

Many employers like a self-certification regime when the consequence of a false statement is only that a participant uses one’s own resources.

But an employer might dislike a self-certification regime when the consequence of a false statement is that a worker gets the employer’s money.

And for employers that prefer a matching contribution over a nonelective contribution, letting a worker get a matching contribution without meeting its conditions might partly defeat one or more purposes about why the employer prefers a matching contribution.

That might be why some employers are considering using intermediaries or software to get some comfort that a worker likely made student-loan payments.

Good points. Thanks for the response.