"To be treated as 'incurred by the employee,' the employee must have a legal obligation to repay the loan under its terms. The Notice explains that a cosigner may have a legal obligation to repay a loan, but a guarantor would not have such an obligation unless the primary borrower defaults.... A plan is not required to have an employee submit verification in support of his or her certification that the qualified education loan is a QSLP. However, a plan may establish reasonable procedures that require independent verification that an employee has made payments on a qualified education loan."  MORE >>