COVID Tax Relief when plan does not choose COVID Options

[RatherBeGolfing]

@EBECatty Agreed.  It has also been very helpful when looking at the loan provisions.  

1 hour ago, EBECatty said:

To the extent the same rules govern 402(f) notices and direct rollovers, if you default to no 20% withholding for plans not offering CRDs, would you also default to no 402(f) notices and no direct rollovers?

There is also a bit of a conflict between plan and individual treatment of distributions. 

The plan can treat a distribution to a qualified individual as a CRD, unless the aggregate distributions from all plans maintained by the employer (and any member of any controlled group which includes the employer) to such individual exceeds $100,000.

The Individual on the other hand, can designate any distribution as a CRD as long as the total amount does not exceed $100,000.  

So if I take $50,000 from my IRA (and intend to designate is as a CRD) and $100,000 from my 401(k), I can only designate $50,000 from the plan as a CRD. The plan can treat the entire $100,000 as a CRD.

Should the plan's default be to treat any distribution to a qualified individual as a CRD as long as it does not exceed $100,000, or should the plan leave it up to the participant to tell the plan if less than 100% of the distribution should be treated as a CRD, and treat the remainder as normal distribution?