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A typical § 403(b) plan has no minimum-distribution provision the plan’s sponsor would change.

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Of the many requests for CARES Act instructions service providers send, some ask whether a plan’s sponsor prefers a halt on minimum distributions.  Some ask that question even of a § 403(b) plan’s sponsor.  Further, some ask the question without considering that the IRS-preapproved document the same service provider furnished makes clear that the plan imposes no involuntary distribution to meet a minimum-distribution requirement.


26 C.F.R. § 1.403(b)-6(e)(2)



26 C.F.R. § 1.408-8



Unlike most BenefitsLink posts, this one asks no question.  I put it here only so those reading for CARES Act ambiguities see another point.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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