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And 30 minutes is what many would consider a great commute...

Plenty of lawyers in this field and on this board who specialize in ERISA law. Intellectual curiosity and insisting that many of the attorneys who specialize and practice in this area everyday might be wrong because an "obscure section of ERISA" that you don't know about that may prove you right are not even remotely similar. Your time is indeed wasted here because you refuse to accept where you are wrong and where your knowledge is limited.

Plans are not required to offer loans in the first place, CARES doesn't change that. It increases the maximum amount of a loan that can satisfy 72(p) but plans which offer loans are currently free to use lower limits than those stated in 72(p) so I don't believe you would be required to increase to the new maximums.

I know now isn't the best time to invent how to get your systems to work while people work from home. But maybe this should be the event that moves your firm to doing that. Most of the TPA firm I work for works from home 100% of the time. I have worked from home since I took my current job back in May of 2012. You couldn't get me to work for a TPA that doesn't allow me to work from home and/or pays me enough I can live in the same town I work in. And even if I live in the same town I worked in I would still want to work from home some. I will never go back to a 30 min commute again unless I am desperate for a job. That was my longest commute and it lasted for 16 years and once I stopped doing it I came to realize how much I disliked it. Most TPA work can be done remotely in my mind. I would add since I started this job and I was the only person in this region we have gained over 8 new clients. I am not in business development and I didn't do most of the work to get the clients. But my presents and speaking at local conferences has gotten the firm I work for a lot more exposure and looks from local ESOP companies. So it has been good for my bottom line and the firm I work for bottom line.

I hate them for never answering the obvious questions when they write these damn things.

Less than 5 employees. Yes, context is always helpful :).

I think you sort have to follow the breadcrumbs in 2202. ... 2202(a)(6)(B) ...a coronavirus-related distribution shall be treated as meeting the requirements of sections 401(k)(2)(B)(i)... 401(k)(2)(B)(i) includes distributable events like termination, death, and disability. 401(k)(2)(B)(i)(IV) references 401(k)(14), which lists amounts that may be withdrawn for hardship distributions. 401(k)(14)(A)(ii) lists qualified nonelective contributions (as defined in subsection (m)(4)(C)). (m)(4)(C)) Qualified nonelective contributions The term “qualified nonelective contribution” means any employer contribution (other than a matching contribution) with respect to which— (i) the employee may not elect to have the contribution paid to the employee in cash instead of being contributed to the plan, and (ii) the requirements of subparagraphs (B) and (C) of subsection (k)(2) are met. I think the above gets us our distributable event and profit sharing. Does that make sense? From there we use 2202(a) to determine if we have a qualified individual and a coronavirus-related distribution.

Had an exchange with an employee today - a client's CPA referred to a client's "Keogh" plan. Our administrator didn't know what that term meant.

The "B" is "benign" but I think that is soft-pedaling it even though technically it distinguishes the condition from more scary alternatives such as cancer. Be content (and continent) in your ignorance.

If that's what it is, I'm glad I didn't know!!!

Generally, no. That doesn't mean it doesn't happen: "Oops! The office manager put the wrong account on the deposit slip so we are just correcting the administrative error". I've seen this a number of times; the argument is that the money is NOT coming back to the employer in any way and is still being used and deducted in the same year. Is it right? Maybe, or maybe not. But I guarantee is it done and I've NEVER seen any repurcussions.