April 23, 2020 – DBZ Webinar – Retirement Plans During the Coronavirus Pandemic:
This post was updated April 3, 2020.
President Trump signed into law the Coronavirus Aid Relief and Economic Security Act (CARES Act) on March 27, 2020. Several provisions in the CARES Act relate to retirement plans.
Plan Sponsors may amend their plans by the last day of the plan year beginning on or after January 1, 2022 to allow for the following:
- Qualified Individuals may receive up to $100,000 of their vested account balance without incurring penalties, even if less than age 59 ½.
- Participants have the option of pro-rating the amount of the distribution included as taxable income over a 3 year period.
- Distributions may be repaid to the plan (or other qualified retirement plan or IRA) within a 3 year period.
- 20% automatic tax withholding is not required.
- The $100,000 is cumulative across all plans offered by an employer or members of a control group.
- Plan may be amended to allow Qualified Individuals to receive a loan of up to the lesser of $100,000 or 100% of vested balance.
- Loans must be taken before September 23, 2020.
- If adopted by the Plan Administrator, a Qualified Individual may request the deferment of scheduled loan payments from March 26, 2020 through December 31, 2020 for up to 1 year.
- The loan must be in good order.
- The 1 year suspension period will be added to the original loan term and include accrued interest.
Qualified Individual is any participant who either:
- is diagnosed with the virus SARS-CoV-2 or with coronavirus disease 2019 (COVID-19) by a test approved by the Centers for Disease Control and Prevention
- has a spouse or dependent diagnosed with the virus SARS-CoV-2 or with coronavirus disease 2019 (COVID-19).
- experiences adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus or disease, being unable to work due to lack of child care due to such virus or disease, closing or reducing hours of a business owned or operated by the individual due to such virus or disease, or other factors as determined by the Secretary of the Treasury (or the Secretary’s delegate).
- Employers may rely on a participant’s certification that they meet the criteria of a Qualified Individual.
Required Minimum Distributions (RMD):
- RMDs for Defined Benefit Plans are still required.
- RMDs for other plans due to be paid in 2020 have been waived.
RMDs from Defined Benefit plans are still required
Defined Benefit Plans:
- Required contributions due in 2020 may be delayed until January 1, 2021.
- Interest must be paid on the contributions from the original due date through the deposit date using the plan’s effective interest rate for the plan year in which the deposit is made.
DBZ FAQs COVID-19: https://www.dbzinc.com/knowledge-center/faqs-covid-19/
Paycheck Protection Program Loan Information: https://home.treasury.gov/policy-issues/top-priorities/cares-act/assistance-for-small-businesses
Coronavirus Tax Relief: https://www.irs.gov/coronavirus