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IRS Ruling on Student Loan Program Under 401(k) Plan Leaves Important Compliance Issues Unanswered
Trucker Huss 
[Guidance Overview] Nov. 1, 2018
"[A] PLR-type student loan repayment program is more expensive for employees than making elective contributions to a 401(k) plan.... [It] is reasonable to assume a student loan repayment program along the lines described in the PLR will be utilized predominantly by nonhighly compensated employees.... How are the nonelective contributions to be tested for coverage and nondiscrimination? Can a student loan repayment program be offered under a safe harbor 401(k) plan? Can a student loan repayment program be offered under a non-401(k) plan?"
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