Thank you to the following who responded to my survey on implementing a loan
program under the 457 Deferred Compensation Plan with ICMA.  Almost all the
respondents except three indicated that the loan provision may not be
allowed in the 457 plan - other respondents were just interested in the
result but did not have this plan in place.

Lancaster - have the plan in place but have never made a loan

Saratoga - indicated they have the plan in place but did not elaborate on
the response

Fremont - indicated they have the plan but they did not obtain a private
letter ruling from the IRS

Indian Wells Valley Water District - according to Tom Mulvihill, their
administrator, Mutual of America, claims that IRS does not allow loans on
457 plan

Camarillo - no loan provision

El Centro - indicated that there is no specific provision in the statute for
a loan option

Porterville - under the impression that IRC code 457 does not allow loans

South Tahoe Public Utility District - understand that Congress never passed
457 plan loans

Berkeley - understand that IRS does not permit loans from 457 plan

Visalia - do not have loan provision in their plan  but interested

Solana Beach - do not have loan provision in their plan  but interested

Rancho Palos Verdes - do not have the loan provision in their plan -  chose
not to when they amended their plan in 98 since ICMA offered little or no
assistance for maintaining and collecting loans

Mountain View - thought there was some question if IRS allowed to do loans
under 457 plan - interested in definite response

El Segundo - do not have the loan provision in their plan

Bill Morgan of Diehl Evans & Company - indicated loan provision is not
covered in the IRS Code - suggested that the City apply for a private ruling
before moving forward (also cited page 106 of the firm's 1999 Government Tax
Manual)

See you all in Pasadena?

Agnes T. Walker
Financial Services Director
City of Redondo Beach
415 Diamond Street
Redondo Beach, CA 90277
(310) 372-1171 ext 2429
Fax (310) 937-6616

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