CARES Act – Retirement Plan Distributions and Loans

Troutman Pepper Podcasts

Troutman Sanders and Pepper Hamilton are producing a series of podcasts to discuss employee benefits, executive compensation, and labor and employment issues that employers are confronting in light of the COVID-19 pandemic, and considerations for employers as they navigate their response to those issues. In this episode, Troutman Sanders partner Mamta Shah and Pepper Hamilton partner Paul Porretta discuss opportunities provided by the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) to offer “qualified individuals” favorable tax treatment for “coronavirus-related distributions” and greater flexibility on plan loan limits and repayment terms in the context of 401(k) plans and other tax-qualified defined contribution retirement plans. Troutman Sanders associate Chris Stock moderates the discussion. Paul and Mamta address the following topics: • The extent to which plan administrators are accepting self-certification of “qualified individual” status, and the form and content required; • Money sources available in participant accounts for coronavirus-related distributions; • Design and administrative considerations; • Amending plan documents and updating summary plan descriptions; • Communicating coronavirus-related distribution and plan loan rules to participants; and • Key open issues pending IRS guidance.