COVID-19 Withdrawal

[thepensionmaven]

Available for DB plans?

I assume plans would need be amended to include a withdrawal provision and then add the $100K COVID-19 language?

[Bird]

Well you can't amend a DB to have in-service before age 59 1/2.  

[thepensionmaven]

True, I was thinking post 59 1/2.

[digger]

An Eligible Retirement Plan refers to the definition in 402(c)(8)(B), which includes a qualified trust. It appears that as long as a DB participant is otherwise eligible for a distribution, up to $100,000 of that distribution can be treated as a CRD.  sec, 2202 (a)(4)(C)

 

4-16-2020 addition: The published analyses are either ignoring the question or saying DB plans aren't included. Who am I to argue? However, I agree with Larry Starr that the plan perhaps cannot treat the distribution as a CRD but the participant may do so on his tax return. (someday I'll learn how to insert links and stuff for reference)