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Using EPCRS to Correct Participant Loan Issues
Belfint Lyons & Shuman, CPAs
Apr. 4, 2017
"Plan failures related to participant loans can be corrected using either Voluntary Correction Program (VCP) or Correction on Audit. Since plan loan failures are not operational failures, they cannot be corrected using the self-correction method.... [P]ossible failures related to participant loans ... include: [1] Plan loans in excess of the maximum limit ... [2] Loan terms do not satisfy repayment requirements ... [3] Loan defaults due to repayments that are not in accordance with the loan term"
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