Cornona Virus distribution

[Lou81]

If the plan allows for Corona Virus distributions.  Can they limit the distribution to be from only sources that are fully vested?

Thanks!

[CuseFan]

Plans can impose whatever limits they want, is my understanding, provided they are applied uniformly without discrimination.

[Luke Bailey]

Just out of curiosity, is anyone familiar with a plan that has ever made any type of distribution of an unvested amount on purpose?

[Mike Preston]

4 hours ago, Luke Bailey said:

Just out of curiosity, is anyone familiar with a plan that has ever made any type of distribution of an unvested amount on purpose?

That wasn't what was being discussed. If the subaccount is less than 100% vested the only amounts includable in the calc are the vested amounts.  Nobody includes unvested amounts on purpose.

[Luke Bailey]

On ‎5‎/‎15‎/‎2020 at 7:37 PM, Mike Preston said:

That wasn't what was being discussed. If the subaccount is less than 100% vested the only amounts includable in the calc are the vested amounts.  Nobody includes unvested amounts on purpose.

OK. Thanks for the clarification, Mike. A lot of plans only have cash-out and buyback provisions, so in many cases you would need to add segregated account language and the reg. sec. 1.411(a)-7(d)(5) formula to handle, but could be done.