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I've got a participant who is confident that they will be brought back from furlough in "three of four months" and wants to start making repayments when they come back.  It sounds like they will be at reduced pay: enough to make the weekly loan repayment, but not enough to 'double up' and catch-up on the missed ones, at least not right away.  Can the CARES suspension period be used for less than a year?  So we'd add a few months of interest accrual and reamortize from the date he came back, but it's not the "1 year" as CARES 2202(B)(2) says.  It seems reasonable...

Posted
1 hour ago, AlbanyConsultant said:

I've got a participant who is confident that they will be brought back from furlough in "three of four months" and wants to start making repayments when they come back.  It sounds like they will be at reduced pay: enough to make the weekly loan repayment, but not enough to 'double up' and catch-up on the missed ones, at least not right away.  Can the CARES suspension period be used for less than a year?  So we'd add a few months of interest accrual and reamortize from the date he came back, but it's not the "1 year" as CARES 2202(B)(2) says.  It seems reasonable...

No problem; the new numbers for the payments shouldn't be cast until the participant is ready to start repayments. And it can certainly be less than a year.

Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC
President
Qualified Plan Consultants, Inc.
46 Daggett Drive
West Springfield, MA 01089
413-736-2066
larrystarr@qpc-inc.com

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