The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was signed into law on March 27, 2020 and included provisions affecting your qualified retirement plan. General information can be found here:

Under the CARES Act, Plan Sponsors may provide “qualified individuals” with additional access to amounts in their retirement plan accounts. Depending on your recordkeeper provider, you may be automatically “opted-in” or must make an election regarding the following CARES Act provisions (please click on your recordkeeper provider link below for their policy and for additional information):

  • Coronavirus-related distributions: Plan will add new distributable event to permit distributions to “qualified individuals” of up to $100,000 (combined limit) during 2020.  Coronavirus-related distributions may be made from all available contribution sources (if a 401(a) plan, excluding money purchase contributions).
  • Coronavirus-related loans: If the plan currently allows loans, the plan will permit loans to “qualified individuals” through September 23, 2020 in an amount not to exceed the lesser of $100,000 or 100% of the participant’s vested account balance. A suspension of loan payments with due dates after March 27, 2020 for a period of 12 months is available to all “qualified individuals”.
  • 2020 RMD waiver: Plan will waive minimum distribution requirements for any distribution required to be made in 2020. Defined Benefit/Cash Balance Plans do not receive relief and are still subject to all minimum distribution requirements.

A “qualified individual” under the CARES Act must meet one of the following requirements (Plan Administrator can rely on a participant’s self-certification):

  • Is diagnosed with COVID-19 by a CDC approved test.
  • Has a spouse or dependent diagnosed with COVID-19 by a CDC approved test.
  • Experiences adverse financial impact due to quarantine, furlough, layoff, reduced work hours or inability to work due to issues with childcare related to COVID-19.
  • Is faced with other COVID-19-related factors as determined by the Secretary of the Treasury.

Please click on your recordkeeper provider for additional information and whether you need to make an election or are automatically “opted-in” as well as links to the applicable forms.

Empower automatically allows for the CARES Act provisions. Additional information and request forms can be found below:

John Hancock will not automatically allow for the CARES Act provisions. Plan Sponsor must complete a letter of direction indicating their elections. Additional information and request forms can be found below:

Lincoln Financial will not automatically allow for the CARES Act provisions. Plan Sponsor must complete the CARES Act Admin Checklist indicating their elections. Additional information and request forms can be found below:

Nationwide will not automatically allow for the CARES Act provisions. Please contact your PBU Consultant if you would like to implement any of the CARES Act provisions. Additional information and request forms can be found below:

Principal will not automatically allow for the CARES Act provisions. Please contact your PBU Consultant if you would like to implement any of the CARES Act provisions. Additional information and request forms can be found below:

The Standard automatically allows for the CARES Act provisions. Additional information and request forms can be found below:

Transamerica automatically allows for the CARES Act provisions, unless the Plan Sponsor elected otherwise. Please have the participant contact Transamerica participant line directly at 1-800-401-8726 and let them know they are calling to request a Corona Related Distribution/Loan.

Voya will not automatically allow for the CARES Act provisions. Plan Sponsor must complete an Authorization form indicating their elections. Additional information and request forms can be found below: