CARES Act FAQ: Retirement Plan Withdrawals

Apr 9, 2020

All information is based on our current understanding as of the date that it is posted. Please keep in mind this information is changing rapidly – it can and likely will change. Some information becomes outdated the same date it posted. Although we will monitor and update this page as new information becomes available, please do not rely solely on this page. We encourage you to contact your Lewis, Hooper & Dick LLC advisor for the latest information.

On March 27^th, President Trump enacted the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The historic $2.2 trillion stimulus bill includes an allowance for penalty-free early withdrawals from retirement accounts.

Below, we address some of the common questions regarding this particular initiative. The changes discussed below may not apply to your plan if the plan document does not allow for early withdrawals and loans. If you cannot find the answer to your question, please do not hesitate to reach out to your Lewis, Hooper & Dick, LLC accounting advisor for further assistance.

What changes did the CARES Act make to retirement withdrawals?

For 2020, eligible plan participants can now receive coronavirus-related distributions from their retirement plans (401(k)-type defined contribution plans or individual retirement accounts (IRAs)).

Individuals aged 70 ½ or retired in 2019 and are required to take their 2019 RMDs from an IRA or a tax-qualified plan in 2020 (by April 1), are not required to take such a distribution in 2020.

Am I eligible to make a withdrawal from my retirement account?

To be eligible, you must fit at least one of the following criteria:

You or your spouse or dependent has been diagnosed with COVID-19, or
You have suffered adverse financial consequences due to COVID-19 (e.g., suffering loss of business, unable to work due to childcare, required to quarantine, put on furlough, etc.)

Plan participants will simply self-certify that they meet the conditions for a coronavirus-related distribution.

How much can I withdraw from my retirement account?

Eligible individuals can take out up to $100,000.

If I make early withdrawals, do I have to pay a penalty?

No, if you make an eligible withdrawal you are exempt from the 10 percent early withdrawal penalty. Additionally, the 10 percent penalty waiver applies retroactively to withdrawals beginning January 1, 2020.

When do I pay taxes on the money I withdraw?

Income taxes are still owed on withdrawn amounts. The CARES Act allows for tax payments to be spread over a three-year period.

Is there a way to re-invest the money that I take out?

Yes, individuals who make coronavirus-related withdrawals may replace the money within three years, regardless of the annual contribution level of their plan. Additionally, they may also be able to recover the federal and state income taxes that they paid.

I already have one or more loans on my 401(k), can I still take a coronavirus-related distribution?

This depends on the particular rules of your plan—consult your plan sponsor.