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July 16, 2026

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Lauren0507 created a topic in 401(k) Plans

Deemed Distribution Made in Error

"A Plan participant was mistakenly terminated in the TPA's system on 9-30-2025, which stopped his loan payments. In November 2025, a 1099-R was issued using Code M (plan loan offset). The error was not discovered until May 2026 after the maximum cure period expired. Since his employment did not terminate, I believe he should have been issued a 2026 Form 1099-R using Code L (deemed distribution). Normally, we would advise the loan be reinstated. However, since the error was not discovered until after the maximum cure period had expired, the TPA is unable to reinstate the loan. The employee was harmed by the error since his loan became taxable. Does anyone have any suggestions as to how this can be remedied under the Plan?"

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