New Deadlines for Retirement Plans, Tax Filings and Paid Leave Policies

The Coronavirus Aid, Relief and Economic Security Act (“CARES”), and IRS and Department of Labor (“DOL”) rules establish new and revised deadlines for retirement plans and other benefit programs.  The following is an outline of key dates:

Item Date
Paid Leave 

Effective date for paid sick and childcare leave under Families First Coronavirus Relief Act (“FFCRA”) for covered employees

April 1, 2020
Reimbursable tax credits under FFCRA for paid leave, cost of healthcare for employees on paid leave and cost of employer-paid Medicare Tax Due Dates for Quarterly Form 941 for FFCRA leave taken after April 1, 2020 and before December 31, 2020
Retirement Plans 

Coronavirus-Related Distributions (“CRD”)

for eligible participants  up to $100,000

Optional – Plans Are Not Required to Offer

CRD Distributions made between January 1, 2020 and December 31, 2020
Participant Loan Maximum Increased from $50,000 to $100,000 New Loans for Eligible Employees taken from March 27, 2020 to September 22, 2020
Participant Loan Repayment – One Year Suspension Applies to Loan Repayment Dates for Eligible Employees between 

March 27, 2020 – December 31, 2020

Plan Amendment for Coronavirus-Related Distributions, Required Minimum Distributions and Loan Changes December 31, 2022 for calendar year plans
401(k) Excess Deferral Distributions July 15, 2020 (extended from March 15, 2020)
Form 5500 No Filing Date Extension for Calendar year Plans 

Form 5500 filings due April 1-July 14, 2020 are extended to July 15, 2020

Defined Benefit Plan 

PBGC 4010 and Premium Payments Due

April 1 – July 14, 2020

July 15, 2020
Defined Benefit Plan 

Minimum Required Funding Contributions Due in 2020

January 1, 2021 – September 15, 2021
Student Loan Debt 

Employer Paid Student Loan Debt up to $5,250

Payments made to lender or directly to employee between March 27, 2020 and January 1, 2021

About the Author: Roberta Granadier is an attorney in Dickinson Wright’s Troy office, where she practices in the area of employee benefits law. She has extensive experience with benefits issues in corporate transactions, executive compensation, ESOPs and public retirement plans. Roberta can be reached at 248-433-7552 or and you can visit her bio here.