CARES ACT - Loans 1 year defer

[52626]

Plan states loans are due an payable at termination of employment

Participants can not continue to make loan payments after they terminated

The cure period for one term participant ends 3/31/2020 and  6/30/2020 for another participant

The CARES Act states if the due date occurs during  the period beginning on the date of the Act and ending on 12/31 the due date shall be delayed for one year.

Questions-

1. Are these participants eligible for the 1 year delay?

2. Does this mean their cure period is 1 year from the 3/31 or 6/30 date?

3. How does the plan document and requirement that loan payments by terminated participants are not accepted impacted by the  CARES Act.  Lay-offs, furloughed participants can they continue to make loan payments, or will the document need to be amended to allow for these payments.

[Luke Bailey]

52626, see the discussion here that includes this issue:

The consensus seems to be (a) a regular loan repayment date, or something close to it, not the end of a cure period, must fall within the CARES Act period to get the extension, and (b) nothing is certain on this or many other CARES Act loan questions until the IRS provides guidance.