Private letter ruling 200213033. Excerpt: [A]n ESOP loan will be exempt from the prohibitions provided in section 4975(c) and the excise taxes imposed by sections 4975(a) and (b) only if the loan is primarily for the benefit of plan participants and beneficiaries.... Substantial contributions to Plan X have been made on a continuing basis since 1997 resulting in a significant repayment of the Loan.