Decisions to Make 1. Communication Strategy What
Develop a strategy for communicating all of the relevant provisions of the FFCRA and CARES Act provisions to employees. Some provisions require formal notification. Other provisions will require formal plan amendments and SPD updates or SMMs (but the formal “due date” for formal ERISA communication is 60 days which isn’t helpful for employees right now). We are suggesting informal communication to employees of the key items they need to know.
A communication strategy for informing employees of the new provisions and entitlements under the laws is critical to ensure that affected individuals know what their new benefits are, and how to access them.
2. Retirement Plan Provisions What
Decisions need to be made on whether (or not) to include the following offerings:
• Waive 10% early withdrawal penalty • Increase maximum loan amount
The CARES Act authorized these changes to be made to retirement plans for participants meeting the COVID-19 qualifications. Employers must individually decide to adopt the more lenient plan provisions for 2020 (or not).
We anticipate that essentially all employers will adopt these more lenient plan provisions to aid employees during financially challenging times.
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