Without our knowledge, an owner-employee S-Corp shareholder took a loan from his plan in 2000. The new EGTRRA regs would exempt this transaction from the PT rules if it were to happen after December 31, 2001. In write-ups on the new rules, I have seen it said that the IRS will also waive penalties for these transactions made before 2002 if the loans would have been allowed had the new law's change been in effect throughout the period of the loan. However, I can't find any official documentation of this. Can anyone help point me in the right direction to determine if I have a problem?