"Taxpayer would make an employer nonelective contribution on behalf of an employee conditioned on that employee making student loan repayments ('SLR nonelective contribution').... If an employee participates in the program, the employee would still be eligible to make elective contributions to the plan but would not be eligible to receive regular matching contributions with respect to those elective contributions while the employee participates in the program.... [The] proposal to amend the Plan to provide SLR nonelective contributions under the program will not violate the 'contingent benefit' prohibition of section 401(k)(4)(A) and section 1.401(k)-1(e)(6). This ruling is based on the assumption that Taxpayer will not extend any student loans to employees that will be eligible for the program." [Issued May 22, 2018; released Aug. 17, 2018.]

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