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Employer Responses to COVID-19: Suspending Employer 401(k) Contributions
Cohen & Buckmann, P.C. Link to more items from this source
Mar. 20, 2020

"Businesses adversely affected by COVID-19 may be considering terminating their 401(k) plans to end their contribution obligations.... [T]he 'successor plan' rule in IRS regulations currently prohibits covering the same employees in a new plan for 12 months following the termination. A plan termination also requires full vesting of all participants and distribution of account balances to the participants, usually within 12 months. A more measured response would be to temporarily suspend or reduce employer contributions."

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