CARES Act Provision Implementation Guide

A quick guide for plan sponsors to implement CARES Act provisions:


  1. Know the basic provisions - Coronavirus related distributions and loans, and a holiday for RMD and existing loan repayments for those with COVID-19 or facing severe financial challenges related to the illness.
  2. Know how your Recordkeeper and TPA service providers are handling these changes. Some are defaulting to opt in for all provisions; some opt out for all; others split - opting in for certain provisions and opting out for the rest.
  3. Decide which provisions are a fit for your team. Generally the withdrawal and RMD provisions are hard to argue against. Depending on current loan policy, plan sponsors may have reasons to decide against the loan provisions. Note, self-reporting of positive testing (self or family) and proof of financial burden falls to the participant.
  4. Determine how providers will help administer CARES Act provisions. Know your administrative duties. Consider systems/processes needed for loan holiday tracking etc.
  5. Make a participant communications plan. Know the options your providers have to assist you with keeping participants informed.


Please don't hesitate to contact us for help!

RWG Advisor Team
(949) 757-1799 /  team@rwg-retirement.com