"[1] It is not clear whether the IRS would permit student loan repayment contributions to be offered under retirement plans other than 401(k) plans. [2] The IRS did not state that the plan sponsor would need to adopt certain student loan repayment substantiation requirements.... [3] It may be administratively impractical for plan sponsors to monitor employee student loan payments ... without the assistance of a competent administrator.... [4] The IRS did not specify whether plan coverage and nondiscrimination testing could be manipulated to prevent student loan repayment contributions from causing plan testing failures."  MORE >>