"[T]he temporary nature of the lockdown that is preventing physical presence, the fact that such a decision is being made during a time of financial stress, the heightened risks of fraud and coercion when the physical presence requirement is not met, and the lifelong, irreversible consequences of cashing out a pension annuity for both spouses, together argue for a substantial but temporary limitation on lump sum distributions from DB plans. Businesses, including notaries, will gradually reopen within a few months, and if a couple wishes to take more or even all of their DB benefit in the form of a lump sum at that time, they will be able to comply with the physical presence requirement and do so."

MORE >>