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Can a Former Employee Roll a Coronavirus-Related Distribution Back into our Plan?

DWC 09/15/20
Facts Earlier this year, we decided to make the CARES Act coronavirus-related distributions (CRDs) available to participant in our 401(k) plan. We know that it is possible for participants to repay CRDs, but we didn’t anticipate any would be interested in that option. We’re glad that some do now want to repay, but we want to be sure we handle ...
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Do We Have to Provide New Paperwork When a Participant Requests a Second Distribution?

DWC 06/16/20
Facts When a participant requests a distribution from our plan, I provide them with a with a package that includes an election form and a bunch of other information.  A participant who terminated and took a distribution last year received an additional company contribution and, as a result, has additional money in her account and is asking for a ...
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Can We Pay Plan-Related Expenses Out of Plan Assets?

DWC 04/28/20
Facts Like many businesses, we’ve been watching our cash flow carefully over the past several weeks.  We’re making adjustments where necessary so that we can stay on top of the invoices we receive from our service providers.  Among those invoices are a few related to expenses for our 401(k) plan.  I think I’ve heard that I can pay those invoices ...
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Should We Include Government-Mandated Coronavirus PTO When Calculating Company Contributions?

DWC 04/21/20
Facts We have several employees who have had to take time off from work either because of a loss of childcare or to care for affected family members due to the coronavirus.  As a result of recent legislation, they qualify to receive compensation during their leave from work.
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The CARES Act Weekly Update | 4.16.2020

DWC 04/16/20
As the conversations surrounding CARES Act provisions continue to evolve, we are constantly updating our FAQs to provide the most in-depth and up to date information. This week, as a result of a lot of hands-on work with our clients to implement these provisions, we have nearly doubled the information available. We've pulled a question from a few ...
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Is There Any Coronavirus Relief for Participants Who Want to Postpone Plan Loan Payments?

DWC 04/14/20
Facts Several participants in our 401(k) plan currently have outstanding plan loans, and many others are looking to initiate them.  However, given the current pandemic, many participants are concerned that they won’t have the funds available to continue making payments right now.
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The CARES Act Weekly Update | 4.9.2020

DWC 04/9/20
This week we took a deeper look into participant's self-certification that they are eligible for relief under the Act, as well as the option some service providers are taking to automatically implement CARES Act provisions for any plan that does not affirmatively opt out. For answers to more questions about The CARES Act or other ongoing effects ...
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How Does the CARES Act Expand the Availability of Retirement Plan Loans?

DWC 04/7/20
Facts Our 401(k) plan allows participants access to their accounts via hardship distributions and, for those at least age 59 ½, via in-service withdrawals.  But with the economic uncertainty of the current environment, participants are now asking about taking loans from their plan accounts.
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Can We Allow a Distribution for a Coronavirus-Related Hardship?

DWC 03/31/20
Facts Some of our employees are dealing with financial challenges due to the coronavirus situation, and they are asking whether they can access their 401(k) accounts.  Our plan allows for loans and for in-service distributions at age 59 ½, but some of these employees are younger than that.  As a plan sponsor, I’ve always felt strongly that our ...
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DWC News Update | The CARES Act: Federal Coronavirus Relief

DWC 03/30/20
On Friday afternoon, March 27th, Congress passed, and the President signed, the Coronavirus Aid, Relief, and Economic Security (CARES) Act - sweeping legislation intended to provide much-needed relief due to the coronavirus public health emergency.  At nearly 1,000 pages in total, the legislation covers a lot of ground in a many areas.  With ...
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The views expressed in this blog are those of the authors and do not necessarily represent the views of any other person or organization. All content is provided for informational purposes only and is not intended to be tax or legal advice.