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How
is a maximum loan calculated if a participant takes out more than one loan
within the last 12 months?
E-mail Alert 2003-24 Rev. 12-16-03
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Assumptions: |
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Participant
has a vested account balance of over $100,000 at all times. |
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Plan permits a
total of up to 4 loans for a participant. |
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Plan does not
limit the number of loans in a 12 month period. |
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The
participant has not had prior loans (and, thus, no loans have been in default). |
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Single
employer with one plan (no control group or affiliated service group
relationships exist). |
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Example 1 |
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Loan 1 |
Loan 2 |
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Loan origination date |
08/19/03 |
12/23/03 |
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Loan Amount Request |
$20,000 |
$10,000 |
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Highest outstanding loan balance in last
12 months as of 12/23/03 |
NA |
$20,000 |
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Maximum amount available for loan on of
12/2303 |
NA |
$50,000 less $20,000 = $30,000*
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*
The amount is the lesser of 50% of the vested account balance or
$50,000 reduced by the highest outstanding loan balance during the
last 12 months. Since the participant had an outstanding loan in the
last 12 months and a vested account balance of over $100,000,
the new loan may not exceed $50,000 less the highest outstanding loan
in the last 12 months. |
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Example 2
Assume everything is the same as example 1
except that in addition to loans 1 and 2, the participant has
unexpected expenses and needs to apply for a third loan on
04/15/04. The participant is requesting the maximum available amount
on 04/15/04, what is that amount? |
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Loan 1 |
Loan 2 |
Loan 3 |
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Loan origination date |
08/19/03 |
12/23/03 |
04/15/04 |
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Loan Amount Request |
$20,000 |
$10,000 |
Maximum available |
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Highest outstanding balance (on any
given day) in the last 12 months before 04/15/04 occurred on
12/23/03 |
$19,120.00** |
$10,000 |
NA |
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Maximum available amount or if less the
amount requested |
$20,000 |
$10,000 |
$50,000 less ($19,120 plus $10,000) =
$50,000 less $29,120 = $20,880*** |
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** |
The $20,000 reduced by loan repayments to $19,120 as of 12/23/03 when
the second loan is at its highest principal amount. |
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*** |
Note that although the two highest outstanding loan balances
during the last 12 months were $20,000 and $10,000 respectively, the
rule asks for the highest outstanding balance on any one day during
the last 12 months. Thus, we resist the impulse to simply add highest
outstanding balances of $20,000 and $10,000 (which would give the
highest loan amounts made during the last 12 months). Instead, we must
use the one day during the year that would reflect the highest
outstanding balance of all the loans when combined together on that
one day. |
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Back
to Hot Topics Index
Bill Grossman, QPA 12-17-03
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