Required Minimum Contribution Deadline extension to 1/1/2021

[NQS]

My understanding is that the extension of the deadline for Required Minimum Contributions until 1/1/2021 is only for defined benefit plans and does not include money purchase pension plans.

Am I correct?

[C. B. Zeller]

Correct.

The text of CARES sec. 3608(a) provides a delay in any minimum required contribution amount determined under IRC sec. 430. Required contributions for money purchase plans are determined under the plan's formula, not IRC 430.

[NQS]

Thanks C.B. for your response. I agree with your understanding of 3608 regarding required minimum contributions. It is also consistent with relief provided defined benefit plans in the past. However even though, I assume,  there are not many money purchase plans still around, I think relief should be provided in this area. Also, I note that some sources describing the relief on contributions to defined benefit plans to 1/1/2001 characterize this relief as simply to pension plans (and leave out  "defined benefit" from their description).