COVID Distributions - Designations and Withholding

As I understand the CARES Act rules re coronavirus-related distributions (CRDs), a distribution that otherwise qualifies for treatment as a CRD can “attain” that status either by (1) the employer designating it as such or (2) the participant treating it as such on his tax return. So, my questions are:

1. How does the employer designate a distribution as a CRD?

2. Can the employer designate a distribution as a CRD without amending the plan, for example where the employer intends that only distributions on employment termination will be designated as CRDs?

3. If an employer does not designate an otherwise qualified distribution as a CRD, does the employer have to withhold 20% even if the participant treats it as such on his tax return?

Thanks.

1. By any reasonable administrative procedure. How does the plan designate a distribution as a hardship distribution? Presumably the plan administrator knows because the participant checked a box for "hardship" on their request form, and provided some substantiation. The same reasoning should apply for a CRD. If the employee checks the box for CRD on their form and attests that they are qualified then the plan administrator can treat it as a CRD.

2. No, the plan has to be amended. Otherwise the plan document will require that the plan provide a rollover notice and withhold 20%.

3. Yes.