Glossary/Government, nonprofit and ERISA

Participant loans

Participant loans let a retirement plan member borrow from their own vested account balance within Internal Revenue Code limits, and they appear on the plan's statements as notes receivable from participants.

CORAA TeamUpdated November 5, 2026

Definition

If the plan document allows, a participant may borrow from the plan without the loan being treated as a taxable distribution, provided it meets IRC section 72(p). The total of the participant's loans generally cannot exceed the lesser of $50,000 (reduced by the highest outstanding balance in the prior 12 months) and the greater of $10,000 or one-half of the vested account. The loan must be repaid within five years, unless used to buy a principal residence, with substantially level payments at least quarterly. A default can be a deemed distribution. On the plan's statements the loan is a note receivable from participants.

Why it matters in an audit or review

Auditors test loan eligibility, approval, and amounts against the plan document and the limits, recompute the balance, test payroll deductions for repayment, and check treatment of defaulted loans. Participant loans also appear in Form 5500 reporting. Loans that do not follow plan terms are an operational failure.

Example

Illustrative: a participant has a vested balance of $70,000 and no prior loans. One-half of the vested balance is $35,000, which is above the $10,000 floor and below the $50,000 cap, so the maximum loan is $35,000.

Common mistakes

  • Not tracking the 12-month lookback on prior loan balances.
  • Failing to report a defaulted loan as a deemed distribution.

Sources

Definitions paraphrase AICPA and FASB guidance; read the standard itself before relying on a requirement. Example figures are illustrative. This page is guidance, not professional advice. Report an error

Standards

ASC 962IRC 72(p)

Related terms

  • ERISA 401(k) plan audit
    An ERISA 401(k) audit is the annual audit of a plan's financial statements by an independent qualified public accountant, required for plans filing as large plans and attached to the Form 5500.
  • Prohibited transactions (employee benefit plans)
    Prohibited transactions are dealings between a retirement plan and a party in interest, such as loans, sales, or services, that ERISA and the Internal Revenue Code ban unless an exemption applies.
  • Plan sponsor
    The plan sponsor is the employer or organization that establishes and maintains an employee benefit plan; it is distinct from the plan administrator and trustee, though one party often holds several roles.

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