Your Plan may have elected to adopt the provisions of the March 2020 CARES Act to allow for Coronavirus-Related Distributions (CRD) and/or Coronavirus-Related Loans (CRL). Please check with your Plan Sponsor if CRDs and/or CRLs are permitted in your Plan. You are an eligible individual if you satisfy one of the following criteria: (1) You, your spouse, or a dependent (as defined in Code section 152) are 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. (2) You, your spouse, or a member of your household have/has experienced adverse financial consequences as a result of being quarantined; being furloughed or laid off; or having work hours, pay, or self-employment income reduced; had a job offer rescinded or a new job’s start date delayed due to such virus or disease; being unable to work due to lack of child care due to such virus or disease; closing or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 you due to such virus or disease; or other factors as determined by the Secretary of the Treasury (or the Secretary's delegate). Note: a “member of the household” is someone who shares your principal residence. You may self-certify to your eligibility on the withdrawal form..
Coronavirus-Related Distributions (CRD):
CRDs must be completed by December 31, 2020 and are available to both active and former Employees. A $100,000 aggregate limit applies on CRDs taken during the 2020 tax year across all Plans and IRAs. The Participant may recognize the taxable income from the CRD over a three-year period that begins when they take the CRD. Please consult an accountant or tax professional for details. The Participant also has the ability to repay the CRD amount tax-free over the next three years and gain tax-free rollover treatment. Please consult an accountant or tax professional for details. Those repayments would not be subject to the Retirement Plan’s annual contribution limits. The repayment will be limited to the amount of the CRD but will not be required to be made to the Plan which issued the distribution. CRDs up to $100,000 are not subject to the 10% early-withdrawal penalty imposed by the IRS on withdrawals before reaching the age of 59.5. CRDs are subject to a 10% federal income tax withholding that is waivable by the Participant on the CRD form (using form W-4P).
Coronavirus-Related Loans (CRL):
CRLs must be completed by September 23, 2020 and are only available to active Employees currently receiving payroll. An eligible Participant is allowed to borrow the lesser of $100,000 or 100% of their vested account balance (reduced by the highest outstanding loan balance, if any, during the prior 12-month rolling period). Repayments on all/any active loans due between March 27, 2020 through December 31, 2020 may be suspended by up to one year with subsequent payments adjusted to take into account the delay. The five-year maximum loan term is also extended for one year. Interest continues to accrue on the loan during the suspension period.
Please visit the Forms section of our website (http://forms.rpgconsultants.com) to download a PDF copy of any distribution or loan withdrawal forms for your Plan. Forms are also available in Spanish by clicking on the 3rd tab on the left-hand side of the Forms page. Please be sure to review the Special Tax Notice which details all tax implications for distributions/withdrawal options.