Delay of Minimum Funding Deadline

[mming]

The CARES Act says that minimum required contributions due in 2020 can be delayed until 1/1/21.  If a calendar year DB plan has a 2019 MRC of $40k due and a maximum allowable contribution of $200k and the employer wants to contribute $100k, a literal interpretation of the Act could imply that $60k would still be due by 9/15/20 while only the $40k MRC can be delayed until 1/1/21.  In other words, the seemingly unintended effect would be that an amount greater than the MRC would be due by 9/15.  Should the new rules be taken to mean that the whole contribution can be deposited by 1/1/21 even if it exceeds the minimum required amount?

[Effen]

The delay doesn't have any impact on deductions or MRC timing.  There was no extension on 5500s or the timing for deductible contributions. 

I agree that if they want to deduct the contribution for 2019, it must be deposited by 9/15/20.  Not just the excess of the MRC, but all of it.   Also, if they don't make the deposit by 9/15/20, they will likely show an unpaid minimum on the 2019 SB.  The excise tax is waived on the unpaid minimum (aka: deficiency), and the IRS/PBGC notification is waived, but I don't think it can be attributed to the 2019 plan year.  

There may be additional relief that changes this, but as it stands currently, if they delay a 2019 plan year contribution until 1/1/21, they can't deduct it in 2019 and they can't show attribute it to the 2019 plan year.  It would need to be treated as a 2020 or 2021 contribution.