"[T]he Treasury Department and IRS have received and are reviewing comments from the public requesting expansion of the list of factors considered to determine whether a plan participant is a qualified individual.... An administrator may rely on an individual's certification in making and reporting a distribution, but individuals must meet the eligibility requirements to treat the distribution as a coronavirus-related distribution on their tax returns. It remains unclear how individuals should substantiate their eligibility.... Even if a plan does not normally accept rollover contributions, the plan does not have to change its terms or procedures to accept [coronavirus-related] repayments."

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