COVID Distributions and vesting

[shERPA]

Normally for plan sponsors who want to provide for in-service distributions, I recommend restricting them to accounts that are fully vested only, just to eliminate a potential error in later determining vesting.

What are people doing/seeing WRT CRDs?  Suppose an employee has $50K in deferrals and $25K in match, 60% vested.  Total vested benefits are $65,000. Limiting CRD to $50K from deferrals only or also allowing up to $15K from match?

[Larry Starr]

On 4/17/2020 at 3:31 PM, shERPA said:

Normally for plan sponsors who want to provide for in-service distributions, I recommend restricting them to accounts that are fully vested only, just to eliminate a potential error in later determining vesting.

What are people doing/seeing WRT CRDs?  Suppose an employee has $50K in deferrals and $25K in match, 60% vested.  Total vested benefits are $65,000. Limiting loan to $50K from deferrals only or also allowing up to $15K from match?

Confused; you start off talking about DISTRIBUTIONS, but then you ask about loans?  They are not the same of course.  I'm referring to CRDs as a special, temporary category of Hardship Distributions. That makes it (IMHO) much easier to talk with clients about.  That is not a loan.  And since all our hardship distributions are limited to ONLY from the deferral account, that's what we are still going to limit them to. 

Maybe that last sentence you meant to say "Limiting DISTRIBUTIONS to $50k...."?

[shERPA]

9 hours ago, Larry Starr said:

Confused; you start off talking about DISTRIBUTIONS, but then you ask about loans?  They are not the same of course.  I'm referring to CRDs as a special, temporary category of Hardship Distributions. That makes it (IMHO) much easier to talk with clients about.  That is not a loan.  And since all our hardship distributions are limited to ONLY from the deferral account, that's what we are still going to limit them to. 

Maybe that last sentence you meant to say "Limiting DISTRIBUTIONS to $50k...."?

Sorry, I meant CRD all the way thru. It was Friday of a long week.  I edited the OP to fix this. 

OK, so you are limiting CRDs to deferral accounts only, got it.  What are others doing?

[RatherBeGolfing]

42 minutes ago, shERPA said:

Sorry, I meant CRD all the way thru. It was Friday of a long week.  I edited the OP to fix this. 

OK, so you are limiting CRDs to deferral accounts only, got it.  What are others doing?

We are still working it out.  Depending on the client, some are doing deferral plus vested balance in other sources, some are deferral only, some declined to offer CRDs completely.