In late June, the IRS released Notice 2020-50, which offers an expanded definition on who is qualified to take advantage of the CARES Act provisions relating to retirement plan* distributions and plan loans. This expanded definition seeks to provide further relief to those affected by COVID-19.

As expanded under Notice 2020-50, a qualified individual is anyone who:

  • is diagnosed, or whose spouse or dependent is diagnosed, with the virus SARS-CoV-2 or the coronavirus disease 2019 (collectively, “COVID-19”) by a test approved by the Centers for Disease Control and Prevention (including a test authorized under the Federal Food, Drug, and Cosmetic Act); or
  • experiences adverse financial consequences as a result of the individual, the individual’s spouse, or a member of the individual’s household (that is, someone who shares the individual’s principal residence):
    • being quarantined, being furloughed or laid off, or having work hours reduced due to COVID-19;
    • being unable to work due to lack of child care due to COVID-19;
    • closing or reducing hours of a business that they own or operate due to COVID-19;
    • having pay or self-employment income reduced due to COVID-19; or
    • having a job offer rescinded or start date for a job delayed due to COVID-19.

Notice 2020-50 also provides further clarification on plan loan amounts and repayment terms administration:

  • Suspension period only applies to payments due between March 27, 2020 and December 31, 2020.
  • Loan payments delinquent prior to these dates are not covered by the CARES Act.
  • All loan payments must resume after the end of the suspension period—no later than January 1, 2021.
  • The loan can be re-amortized to reflect a final payment/due date with a new due date—not to exceed one year after the original loan terms.
  • Loan payment suspension is only available to qualified individuals and requires a signed self-certification form.

Additional Resources

To stay up to date regarding COVID-19 related items, check out our CARES Act Resources page.


Important note: Money Purchase Plan (MPP) funds do not qualify for CARES Act relief.

*These updates impact MidAmerica Special Pay, 3121 FICA Alternative, APPLE, Employer Sponsored or Single Vendor plans.


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