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Coronavirus-Related Distributions: Requirements and Practical Considerations
Ice Miller LLP Link to more items from this source
[Guidance Overview]
May 11, 2020

"Some vendors implemented an 'opt-out' approach for the plans they administer, while others implemented a more conservative 'opt-in' approach. Accordingly, it is possible that CRDs were permitted in operation from a retirement plan before a plan sponsor had time to consider whether to adopt this optional provision.... [In] many cases there will be very little effective oversight as to whether the employee truly meets the criteria of a qualified individual, making this an in-service distribution option that could be exercised by potentially any employee."

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