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Participant Loan Repayments Become Plan Assets As Soon As They Can Be Segregated from General Assets
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL] 
May 30, 2002
Advisory Opinion 2002-02A (May 17, 2002). Excerpt: [I]t is the Department's opinion that participant loan repayments, made to the employer for purposes of transmittal to the plan or withheld from employee wages by the employer for transmittal to the plan, become plan assets as of the earliest date on which such repayments can reasonably be segregated from the employer's general assets.
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