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401(k) Plans During the COVID-19 Pandemic
Blank Rome LLP Link to more items from this source
Mar. 19, 2020

"If an employer ... had not included a statement in this year's safe harbor notice that the employer was reserving the right to suspend or reduce safe harbor contributions, the employer will be required to rely upon the economic loss exception.... Workforce reductions, in the form of furloughs, and severance benefits raise planning issues with respect to participant loans.... Under the IRS safe harbor, hardship withdrawals may only be made for certain categories of enumerated expenses and, therefore, cannot be made solely as a result of a reduction of hours or a furlough."

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