"[T]he delayed repayment rule may create recordkeeping and participant communication challenges and should be coordinated with any rules a plan has regarding when a loan is considered in default ... Guidance from the IRS would be helpful as to: [1] whether employees can self-certify that they meet the conditions to be a qualified individual; [2] whether a plan is required to provide the one-year delay for loan repayments; and [3] whether the relief applies to loans which would otherwise be defaulted."  MORE >>