401K Loans in two different plans for the same employer

Hello! I would like to get your input.If there is an outstanding 403B loan for example 15k in Vanguard. The employer switch to a new carrier and now 100k of 401 money is moved to Fidelity. If a new loan is processed with the new services, would the 50k IRS limit apply? The loans are in two different service providers but in the same employer's 403 B plan. Your input is highly appreciated. Thank you. 

are you saying the employer switched recordkeepers?  Why did some of the assets move, but not all? Why did they not move the loan balance?  Is payroll going to be sending loan repayments to both every payroll (- that's a payroll and recordkeeping nightmare)?  The situation as you pose it is a bit odd.  The only time I have seen money stay is when it is possibly in an investment that has withdrawal stipulations (we had some money that had to stay at TIAA due to that), but a loan balance would not be that.    

Based on what you have provided, it's still the same plan and the limits are on the  plan, not on where the money is stored. So I would say yes, the 50k limit would apply.  Maybe someone else will correct me if I am wrong, but I am the only one that thinks this setup to be very odd?

3 minutes ago, rr_sphr said:

Based on what you have provided, it's still the same plan and the limits are on the  plan, not on where the money is stored. So I would say yes, the 50k limit would apply. 

Correct. Even if they were separate plans (and it's not clear if we are talking about 401(k)s, 403(b)s, or both) all loans under all the plans of the employer (including controlled group/common control/ASG plans) would be aggregated for purposes of the $50,000 limit.

Thank you, that is very helpful. The employer switched the 403 B to another vendor (VOYA to Lincoln). I understand that it is essentially the same plan.  I think the same way too, that since the employer is the same, and the plan refers to the 403B plan regardless of the administrator or service provider, the 50k limit most likely will apply. Thank you for your insights. 

If ERISA 403(b) then employer is responsible for monitoring compliance with that, and if non-ERISA, I believe employer is supposed to get info-sharing agreements among the vendors so that these limits can be properly monitored between them - if I remember correctly (not a 403b practitioner and know enough to be dangerous!).