Loan Refinance under COVID Rules?

Plan's loan program allows a participant to refinance their existing loan.  Currently allows for only one outstanding loan.

Under the "normal" rules, the participant has a small amount of cash available in a refinance transaction.

If the Plan adopts the Covid loan rules, and assuming the participant is a qualified individual, can they refinance the existing loan using Covid expanded loan limits and payment suspension?

As a follow up, I've seen it indicated elsewhere that a plan that does not normally allow for loans can adopt the Covid loan rules and allow Covid related loans only.

Is it a stretch then in a situation like this, that the Plan could allow for a new Covid loan by adopting the Covid rules and maintain the one "normal" loan restriction? 

So in the example, the participant would be permitted to have one normal loan and one Covid loan, without having to change the "normal" loan policy and would then not need to refinance the existing loan?

Thanks very much.

All reasonable courses of action.  Just keep track and incorporate the decisions into the good faith amendment that is required at some point (circa 12/31/2022).

Thank you Mike.

mike, how would the COVID loan work in terms of the limit if he already has an existing loan. lets say his account balance is 100k but he already has an existing loan.  i i am guessing he can take 100% less the amount of the existing loan?

Your guess is as good as mine at this point.  I'd be tempted to use 100k reduced by the highest outstanding balance in the last 12  months.  I recognize that is a pretty conservative route.