CARES Act Administrative Q&As

The American Retirement Association has recieved numerous questions regarding the administration of the retirement provisions of the CARES Act. As we continue to work with regulators to achieve clarity and receive guidance on this legislation, we wanted to respond to your questions, and provide you with our most current understanding. We have organized the questions into several broad categories and created a downloadable PDF for each or you can download the complete Administrative Q&A document. These FAQs were updated as of July 1, 2020.

General Questions
Broader issues arising in the administration of the provisions of the CARES Act.

COVID-19 Distributions
Key elements of the new distribution rules: eligibility & adoption, administration & reporting, participant notices, and distribution repayments.

COVID-19 Loans
Eligibility & adoption, administration & reporting, notices, and repayment extension questions for the optional provisions allowing increased loan amounts. 

RMD Waivers
The CARES Act waives the requirement for any required minimum distribution (RMD) in 2020 - this section covers eligibility & adoption, administration & reporting, and rollovers related to RMDs.

Plan-Type Specific
Questions specific to safe-harbor plans, SIMPLE plans, government plans, defined benefit and cash balance plans.