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Rick

CARES Act Delayed Contributions - Credit Balance Elections, Schedule SB, and PBGC filing

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These questions are in regards to the CARES act delaying the due date for all required payments during the 2020 calendar year to January 1, 2021.

Are credit balance election due dates also delayed until January 1, 2021?  My understanding is that the credit balance election must be made by the contribution due date.  Since the contribution due date has been delayed then the ability to elect to use credit balances would be delayed as well.

Also, If a client decides to delay their 2019 residual contribution to January 1, 2021, then how does this affect Schedule SB and PBGC filings?  Would one file the forms without the residual contribution, possibly showing an unpaid minimum on the Schedule SB, and then revise the forms later once the final payment has been made?  An extra attachment to the SB stating that it will be revised after the final contribution has been made could be added as well.  

I believe there is not yet much guidance on this, but would like to know if others agree with those statements or are taking a different approach.

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