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Multiple Loans from Unrelated Employers


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    We have a client with a 401(k) plan and a participant wants to take a $50,000 loan which he is eligible to do. He also has a second job that is totally unrelated to this client and that job has a 401(b) plan that allows loans. Can he also take a $50,000 loan from the 403(b) plan? I cannot find anything that says he can't but I might be missing it. 

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    The loan limit applies within a controlled group of employer's retirement plans, so I think he is OK. I know there is some aggregation if the person is the business owner on the 401(k) side because he is also considered the "owner" of his 403(b) but not sure if that is only a 415 issue. If he is an owner I'd dig deeper, otherwise I think he's good to borrow.

    Kenneth M. Prell, CEBS, ERPA

    Vice President, BPAS Actuarial & Pension Services

    kprell@bpas.com

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