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New client has outstanding loans with missed payments. Some loans have not been paid on at all going back a year.

I was going to give the following options to the client for correcting. Please let me know if there are any issues with these:

1. Catch up loans for all missed payments including interest and start loan payments on next payroll.

2. Re-amortize loans, with new start date but same end date as original loan so it is still paid off within 5 years of the loan origin. If this is allowed, the interest rate of the original plan was higher than the current so I would re-amortize using the current (lower) interest rate.

3. Have participants take out a second loan for the missed payments, and contribute the money back to the plan and start both loans on next payroll. (assuming the plan allows for 2 loans and the second loan does not exceed the limit based on their balance or $50k)

4. Have 59.5 employees take in-service distribution (trued up for taxes) for missed loan payments, and contribute the money back to the plan.

Note: none of these loans are for HCEs.

 

 

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