"If you intend to allow for COVID-19 related distributions in 2020, a new distributive event would have to be created that is not subject to the 10% early distribution penalty tax or mandatory 20% withholding.... If COVID-19 distributions are being repaid to your retirement plans, procedures must be in place to treat any such payments as rollover contributions and limit such repayments to the aggregate amount of distributions that the individual received from all retirement plans in your controlled group."