ICI Sends Treasury List of Questions on CARES Act/COVID-19 Relief Related to Retirement Plans

[32430]

May 1, 2020 TO: ICI Members
Pension Committee
Pension Operations Advisory Committee SUBJECTS: Pension RE: ICI Sends Treasury List of Questions on CARES Act/COVID-19 Relief Related to Retirement Plans

 

ICI shared with the Treasury Department the attached list of issues relating to the retirement savings provisions in the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act)[1] and other COVID-19 relief.

The list includes questions relating to the CARES Act’s waiver of required minimum distributions for 2020, special coronavirus-related distribution and plan loan rules, and plan loan repayment suspension. It also includes questions relating to the deadline extensions provided in Notice 2020-23[2] (including Form 5498 filing and the temporary extension of plan loan repayments) and it recommends relief from (1) the requirement to send revised, mid-year safe harbor notices if a safe harbor plan adopts a coronavirus-related distribution provision and (2) the 30-day advance notice requirement for safe harbor plans seeking to suspend or reduce matching contributions.

Finally, in recognition of the significant efforts already made by plan and IRA providers to implement provisions of the CARES Act, we urge that Treasury and IRS guidance should incorporate principles of flexibility and good faith reliance.

 

Elena Barone Chism
Associate General Counsel - Retirement Policy
 

Attachment

endnotes

[1] See ICI Memorandum No. 32328, dated March 27, 2020, available at https://www.ici.org/my_ici/memorandum/memo32328.

[2] See ICI Memorandum No. 32391, dated April 15, 2020, available at https://www.ici.org/my_ici/memorandum/memo32391.