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 RGranadier@dickinsonwright.com and you can visit her bio here.
