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Posted

A plan has a fraud prevention procedure that delays issuing a participant loan request by a couple of days after the request is made. A participant's vested balance is $10,000 on the day they request a $5,000 loan. The market drops during those 2 days so their vested balance is $8,600 when the loan is issued.

Can the plan issue a loan for $5,000 or must they redo the amort schedules etc. and only issue a loan for $4,300?

Posted

Okay, found this:

The issue is when the plan document requires 'daily valuation'.If the loan policy has language that allows some reasonable procedure, would that allow the $5,000? It is not exactly addressed in IRS Notice 82-22. Opinions welcome.

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