I think it will eventually become loose over time through normal wear and tear. If one continually takes out and reinserting the pen, the slot holding the pen will loosen up. It will come to the point where it will just slide out. I know all my old units have a loose stylus slot. Just tip the device and the stylus just slides out. The catch on it is gone or just worn out. I can see this eventually happening with the Note S Pen.
Which is why I went ahead and got the S Pen holder and MS Surface Pen. To prevent me from taking the S Pen out of the slot and reinserting it back in. Also better ergonomics.