Coronavirus-Related Distributions - Mandatory Distributions

[EBECatty]

Does anyone have thoughts on whether distributions that would otherwise be required before December 31, 2020, could qualify as coronavirus-related distributions?

For example, a plan has a mandatory distribution for terminated participants who reach normal retirement age. If the participant reaches NRA next week, can they certify they have been impacted and receive the first $100,000 as a coronavirus-related distribution? 

Or existing ESOP installment payouts? Say a participant was scheduled for an installment payment to be made this summer. If they certify they have been affected, is the first $100,000 treated as such?

Assume each plan is willing to accommodate by operating and subsequently amending the plan in accordance with the new provisions. 

[Mike Preston]

I don't see why not.

[RatherBeGolfing]

Agreed.   

Per 2202(a), a coronavirus-related distribution is any distribution up to $100,000,  made from an eligible retirement plan , made on or after January 1, 2020 and before December 31, 2020 to a qualified individual.

As long as it meets 2202(a) it should qualify.