S. Weekley

It is my understanding from the above that you believe an employee that terminated prior to the CARES Act for reasons other than COVID-19 can take a distribution from the plan and utilize the 10% penalty waiver as well as paying the taxes back over 3 years (ie, no 20% mandatory withholding)? If the COVID 19 distribution is a hardship distribution, it doesn't seem logical that a previously terminated employee could benefit. Thoughts?

I was 99.9% positive that it needed to run through the trust but wanted to make sure I was not missing anything. And I totally agree that the sponsor needs a new brokerage company. It has been a real pain to deal with over the past several years!!!!!

I have a terminated employee who was due an employer match after termination. The entire participant account balance was distributed prior to the match deposit and the account closed. There has been a lot of hassle trying to get an account reopened in order for the match to be deposited and then distributed to the participant. The broker is saying that the plan sponsor can just write the check directly to the participant and there is no reason to reopen the account. I have searched and searched but cannot find any guidance on how to handle this. Any thoughts or guidance would be appreciated.