Mike Preston

Wish. Granted.

I think it was you. I'm not one of the 10 people that have downloaded it, to date. Hardly time sensitive.

Yes.

I think it has been discussed. As I recall, somebody posted a spreadsheet. When re-commenced, you re-amortize over the period that ends 1 year after the original 5 year period ended.

If not otherwise specified, use 7. Then change it later in the year when we get guidance, if necessary.

At this moment when selecting California it shows both Individual and Public Assistance but there is a dollar amount showing up only under Public Assistance. If the Individual Assistance section only displays what is shown below does that mean no COVID-19 hardships are available? "Individual Assistance - Dollars Approved If and when individual assistance money is approved for this disaster, it will be displayed here. Information is updated every 24 hours."

Except for DB plans.

All reasonable courses of action. Just keep track and incorporate the decisions into the good faith amendment that is required at some point (circa 12/31/2022).

From individual account plans (401(k), PSP, IRA, etc.). Not DB plans.

I don't see why not.

1. Yes, if the plan sponsor wants to make it so. An amendment will be required by 12/31/2022 that conforms the plan to the plan sponsor's wants. 2. Yes, if the plan sponsor wants to make it so. An amendment will be required by 12/31/2022 that conforms the plan to the plan sponsor's wants. 3. None, a signed statement from the participant stating that the participant meets the criteria is sufficient. 4. Yes, if the plan participant signs a statement stating that the participant meets the criteria. 5. Yes, if the plan participant signs a statement stating that the participant meets the criteria.

I think it is potentially abusive to ignore the loss. There is no specific method laid out in guidance as to exactly how to take the loss into account. So just do something reasonable. Keep in mind that some day the plan sponsor might need to answer the question: what would compensation have been had the loss been a $10,000 gain?

I think it is highly likely that compensation for the period 4/1/2019 through 3/31/2020 will be used by the plan which now covers all three employers. A certainty for 415 purposes and top-heavy and some parts of gateway (if applicable). Most likely for plan benefit purposes, too, but this is rebuttable by merger documentation.

Wave's hand in air and says: Move along.

Unless it is a db plan.

Because all plan provision changes require an amendment at some point.

The plan fiduciaries have to make that call.

You need to talk to a lawyer. Nobody here can give you the in depth answers you are looking for. With that said, it is highly unlikely that you are entitled to 5 years of payments in one fell swoop. The good news is that the way qdro's are typically drafted you will probably be entitled to higher monthly payments at 60 than you would have received at 55. Good luck.

No. The employer can't know, period.

Both are optional provisions. That is, the employer may choose not to allow either.The law is ahead of you as far as privacy is concerned because the participant only needs to say that they are qualified to receive either the increased loan or distribution and the employer / plan sponsor can take the employees word.

Is there anything that substantiates the position that the hardship is limited to circumstances involving the plan sponsor? I certainly haven't seen anything.

Not true. You can always complete the Sch SB on time and show a deficiency which gets eliminated in the next year's filing.

Can't follow what you are saying, precisely, but the best thing for you to do is to read 1.401a9-6 and pay close attention to when the DC RMD calculation can be used in a DB plan. CARES does absolutely nothing for DB plans.

To do what you describe would directly contradict 1.401a9-6 which talks about doing something close to what you describe but requires a double up, if applicable. Note: REQUIRES.

TL,DR