Coronavirus-Related Distributions and Loans under the CARES Act

Recently, pursuant to Section 2202 of the CARES Act, the Internal Revenue Service issued Notice 2020-50 to provide guidance to employers, plan administrators and plan participants regarding coronavirus-related distributions and plan loans from eligible retirement plans. QHow does the CARES Act define "qualified individuals" who are eligible for coronavirus-related distributions and plan loan relief? A Section 2202(a)(4)(A)(ii) of the CARES Act defines a "qualified individual" as an individual: * who is diagnosed with the virus SARS-CoV-2 or with coronavirus disease 2019 (referred to collectively as COVID-19) by a test approved by the Centers for Disease Control and Prevention (CDC); * whose spouse or dependent is diagnosed with COVID19 via a CDC-approved test; * who experiences adverse financial consequences as a result of: □ the individual being quarantined, being furloughed or laid off, or having work hours reduced due to COVID-19; □ the individual being unable to work due to lack of childcare due to COVID-19; or □ closing or reducing hours of a business owned or operated by the individual due to COVID-19. QDoes Notice 2020-50 expand the list of factors that will cause a person to be a qualified individual for coronavirus-related distributions and plan loan relief? A Yes, the notice expands the definition of "qualified individuals" to those who experience adverse financial consequences as a result of: * the individual having either a reduction in pay (or self-employment income), a rescinded job offer, or a delayed job starting date due to COVID-19; * the individual's spouse or member of the individual's household being quarantined, being furloughed or laid off, or having work hours reduced due to COVID-19, being unable to work due to lack of childcare due to COVID-19, having a reduction in pay (or self-employment income) due to COVID-19, or having a job offer rescinded or a job starting date delayed due to COVID19; or * closing or reducing hours of a business owned or operated by the individual's spouse. In order to obtain such relief, a plan administrator accepting the recontribution of a coronavirusrelated distribution must reasonably conclude that the recontribution is eligible for direct rollover treatment under section 2202(a)(3) of the CARES Act and that the recontribution is made in accordance with applicable rules of Notice 2020-50. [...]a plan administrator may rely on an individual's certification that the individual satisfies the conditions to