"Am I the first one to see this? Under the safe harbor in IRS Notice 2020-50, a qualified employer plan will be treated as satisfying the requirements of Section 72(p) pursuant to section 2202(b)(2) of the CARES Act if a qualified individual's obligation to repay a plan loan is suspended under the plan for any period beginning not earlier than March 27, 2020, and ending not later than December 31, 2020 (the 'suspension period'). The loan repayments must resume after the end of the suspension period, and the term of the loan may be extended by up to 1 year from the date the loan was originally due to be repaid.

'I was wrong.' They even said you can do the crazy thing of suspending through Dec 31, making the regular payments until the 1 year mark for the suspension, and then reamortize what is left.

'I was totally wrong.' At least we know what we have to do."

"I don't think the participants can win this, but if you've been sued you've lost as a practical matter. Monday morning quarterbacking it -- the employer communicated poorly (I'm not a lawyer but it seems that some of those communications might have left them exposed), and has totally dropped the ball on moving assets to cash when it KNEW these distributions were pending."

"I'm curious to hear your opinions on this lawsuit: Lipshires v. Behan Bros. Inc. Retirement Plan, No. 20-252 (D.R.I., complaint filed Jun. 8, 2020)."

"If 2 plans are part of a controlled group, but on occasion an employee might be terminated from one employer and hired by another, is that a distributable event? Can the individual roll their balance from one plan to the other?"

"401k plan is sponsored by OwnerCo. -- Owner also works for another company ('EE-Co.') as an employee. Owner is over age 50. Owner will defer $6,000 in the EE-Co 401(k) plan.Owner will receive $22,000 salary from OwnerCo and will defer $20,000 into the OwnerCo 401(k) plan. So, between the 2 deferrals, Owner will not exceed $26,000 for 2020. Of the $20,000 deferral into the OwnerCo plan, the owner will treat $6,500 of the deferral as catch-up, which reduces the base deferral to $13,500. Owner also will get a $5,500 profit sharing allocation in the OwnerCo. plan. Therefore: $13,500 + $5,500 = $19,000 ... which will not exceed 100% of pay (i.e., $22,000). Agree?"

"To the extent a plan has had a partial termination and it goes back to restore the forfeited account balances of the terminated participants, does it need to credit those account balances with investment earnings for the period between the forfeiture and the restoration? Any authority for this?"