EBECatty Posted April 1, 2020 Share Posted April 1, 2020 Does anyone have thoughts on whether distributions that would otherwise be required before December 31, 2020, could qualify as coronavirus-related distributions? For example, a plan has a mandatory distribution for terminated participants who reach normal retirement age. If the participant reaches NRA next week, can they certify they have been impacted and receive the first $100,000 as a coronavirus-related distribution? Or existing ESOP installment payouts? Say a participant was scheduled for an installment payment to be made this summer. If they certify they have been affected, is the first $100,000 treated as such? Assume each plan is willing to accommodate by operating and subsequently amending the plan in accordance with the new provisions. Link to comment Share on other sites More sharing options...
Mike Preston Posted April 2, 2020 Share Posted April 2, 2020 I don't see why not. Link to comment Share on other sites More sharing options...
RatherBeGolfing Posted April 2, 2020 Share Posted April 2, 2020 Agreed. Per 2202(a), a coronavirus-related distribution is any distribution up to $100,000, made from an eligible retirement plan , made on or after January 1, 2020 and before December 31, 2020 to a qualified individual. As long as it meets 2202(a) it should qualify. Link to comment Share on other sites More sharing options...
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