CARES Act Impact on Qualified Retirement Plans and Other Considerations for Defined Contribution Plans
The coronavirus disease 2019 (“COVID-19”) continues to put significant pressure on employers to navigate various employee issues, including with respect to retirement plans. In the provisions of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) that cover qualified retirement plans, Congress has provided additional tools to plan sponsors and relief to both plan sponsors and participants, including penalty-free distributions, plan loan relief, a temporary waiver of required minimum distributions for defined contribution plans, and temporary funding relief for single-employer defined benefit plans. Each of the foregoing is discussed in this memorandum. This memorandum also addresses selected issues related to defined contribution plans that employers and plan fiduciaries may face as a result of the COVID-19 crisis.