"While [Rev. Proc. 2019-19] provides welcome relief for the most common loan failures, there are several loan-related errors that still require formal IRS approval. [1] Loans that exceed statutory maximum amount -- generally 50% of a participant's vested balance; [2] Loans that exceed the statutory limit as to duration -- five years unless for the purchase of a primary residence; [3] Requests to have a deemed distributed loan taxed in the year of correction rather than the year of the failure; and [4] Corrections that also qualify for DOL approval.... Even though the IRS now accepts self-correction of certain loan failures, the DOL still does not."