Can delinquent transmittal of participant loan repayments be included on Line 4a, or must they be reported as nonexempt prohibited transactions on Line 4d and Schedule G?

In Advisory Opinion 2002-02A, the Department stated that participant loan repayments paid to or withheld by an employer for purposes of transmittal to an employee benefit plan are sufficiently similar to participant contributions to justify, in the absence of regulations providing otherwise, the application of principles similar to those underlying the participant contribution regulation for purposes of determining when such repayments become assets of the plan. Delinquent forwarding of participant loan repayments is eligible for correction under the VFCP and PTE 2002-51 on terms similar to those that apply to delinquent participant contributions. Accordingly, the Department will not reject a 2003 Form 5500 report based solely on the fact that delinquent forwarding of participant loan repayments is included on Line 4a of the Schedule H or Schedule I.

Filers that choose to include such participant loan repayments on Line 4a must apply the same supplemental schedule and IQPA disclosure ... more.

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