participant loans (large minimum)

Regs say 1,000 limit is ok but what about 5,000 limit. plan has few if any HCE's.  does this fail the rights benefits features test or the reasonably  equivalent basis test?

I wouldn't do it.  The 'reasonably equivalent basis' is prohibited transaction standard.  For that matter, so is not discriminating in favor of HCEs. In theory, as soon as you hire an additional employee who reaches a vested balance of $2,000, your loan program would become a prohibited transaction.  That would be my initial thought.

Good Luck!

Unless your document is an IDP, I would think the $1,000 ceiling for a minimum would be written in already.

I think the link below has a nice discussion on this issue with some issues raised on limits above $1,000.  BG5150 responded to the other one as well....almost 8 years to the day.

https://benefitslink.com/boards/index.php?/topic/44548-minimum-loan-amount/