Does anyone know of any provision limiting the "quarterly" repayment requirement to calendar quarters only? For instance, if a loan was made in December 10, could the first quarterly payment be due on February 10? Or is the initial "quarterly" payment due December 31?

I usually saw the repayments started on a calendar year (March 31, June 30, September 30, December 31) schedule, even if the loan was made mid-quarter. However, nothing wrong with going on even 3 month intervals. Just more administrative work for the employer/recordkeeper.

What do the regulations say?

The only thing I recall reading in the Regs. paraphrased of course, is that payments may not be made less frequently than on a quarterly basis. I don’t recall ever reading that this must be on a calendar quarter. However, after having said that, I wonder if quarterly means at least every three months or every 90 days or does it in fact mean a calendar quarter. These days, quarterly may mean whatever you interpret quarterly to mean to you. Right Bill?

I agree, quarterly is open to interpretation.