"[1] Participant student loan repayments will not count toward [ADP] testing and the related employer non-elective contributions will not count towards [ACP] testing.... [2] The right to receive a non-elective contribution as a result of making a student loan repayment must be both currently and effectively available on a nondiscriminatory basis.... [3] [T]he fact that [generally non-highly compensated employees] are making student loan repayments rather than 401(k) elective contributions may negatively affect ADP or ACP testing results, reducing the amount that could be contributed by/for highly compensated employees.... [4] [S]tudent loan repayments ... would generally have to be made on an after-tax basis. As a result ... student loan repayments will, in effect, 'cost more' (to the participant) than regular 401(k) contributions."  MORE >>