If one of your 403(b) participants applies for a loan from her account, but the account was written when the company held a payroll slot with a non-ERISA employer, what do you do? And does it matter if you received contributions to the account after Jan. 1, 2005, but it was deselected by Jan. 1, 2009?
Under Revenue Procedure 2007-71, you may deal directly with participants for such requests. In the second installment of "Tech Talk," Ellie Lowder tells you how that can be, and what the answer is under circumstances that may seem to put your ability to meet the request in question.
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