RAH401(k)

Out of curiosity, how was she able to enter an election specific to catch up contributions if the recordkeeping system doesn't track catch up and deferrals separately?

My understanding is that he might be able to. If he meets the criteria to be considered a "qualified individual" as outlined in the CARES Act, couldn't his RMD from earlier this year qualify as a Coronavirus Related Distribution as defined by the CARES Act, which would allow him the ability to pay it back and not take the tax hit? If he doesn't meet the criteria, then I do think he is out of luck.

I agree with mattmc82. The CARES Act does not impact if/how many loans are allowed by the plan document. If the plan does not allow loans, it could choose to allow them at this time, or not. If a plan only allows three loans (or one loan), the CARES Act doesn't change that. A Plan Sponsor could certainly choose to amend the number of loans allowed at one time, but the CARES Act does not do this automatically.

As long as they have the documentation to prove the actual need for both, and the exact dollar amounts, this shouldn't be an issue.

Thank you, Larry!

When is a contribution considered to be made "by the tax filing deadline?" in regards to being deductible for that plan year? We have a client who waited until the last day to file their taxes - and to submit their annual employer match on that same afternoon. The submission missed the record-keeper's daily cut-off for the ACH pull, so funds were not pulled from the employer bank account until the next day - the day after their tax filing deadline. The funds were deposited to the plan's trust the following day. Is the contribution considered "made" when the transaction is submitted online? Or when the ACH actually pulls? Or when the assets are actually deposited to the trust? Thank you for any assistance!