FAQs on how the CARES Act may affect you | Capital Group

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May 5, 2020

FAQs on how the CARES Act may affect you

The stimulus bill known as the CARES (Coronavirus Aid, Relief, and Economic Security) Act was signed into law on March 27, 2020. The act is designed to help mitigate the impact that coronavirus (COVID-19) is having on the U.S. economy and includes temporary relief specific to certain types of transactions in IRAs and retirement plans.

The provisions:

  • Waive required minimum distributions (RMDs).

    RMDs for 2020 are waived for all types of defined contribution plans and IRAs including:

    • Traditional, Roth, SIMPLE, SEP and SARSEP IRAs
    • Inherited IRAs
    • 401(k)
    • 403(b)
    • Governmental 457(b) plans

The waiver also affects 2019 RMDs for individuals who attained age 70 ½ in 2019 and deferred their 2019 RMD payment until April 1, 2020. If the individual did not distribute their RMD in 2019, then the waiver applies.

  • Creates special tax rules for coronavirus-related distributions (CRDs) up to $100,000.
    • Relief from required 20% withholding on CRDs
    • Income from CRDs can be taken into account for tax purposes over three years
    • Waives early distribution penalty tax (typically 10%)
    • Allows for rollovers back within three years and, if rolled back, then reversal of any income tax paid on CRD

The distribution must be taken on or after January 1, 2020, and before December 31, 2020. The maximum amount for an individual across all their plans and IRAs is $100,000.

The Act defines an eligible individual as someone:

  • Who is diagnosed with the virus SARS-CoV-2 or with coronavirus disease (COVID-19) by a test approved by the Centers for Disease Control and Prevention,
  • Whose spouse or dependent (as defined in Code section 152) is diagnosed with such virus or disease, or
  • Who experiences adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus or disease, being unable to work due to lack of child care due to such virus or disease, closing or reducing hours of a business owned or operated by the individual due to such virus or disease, or other factors as determined by the Secretary of the Treasury

Some of the provisions will be subject to future guidance. We will provide more information as it becomes available.

Frequently Asked Questions

The following is meant to highlight some of the key changes that impact individual retirement accounts (IRAs) and employer-sponsored retirement plans.

Required Minimum Distributions (RMDs) Waiver

Q: I have automatic payments established for the 2020 RMD. Will the RMD be automatically deferred?

A: No. Investors and/or advisors need to direct us to modify or defer an automatic withdrawal plan. We can take the request verbally or in writing.

 

Q: I already took a 2020 RMD payment from my IRA. Can it be returned?

A: If it’s within the 60-day indirect rollover period, a distribution taken earlier this year to meet a 2020 RMD requirement is eligible to roll over back into the IRA. Investors should complete the Indirect Rollover Request. Current law only allows one rollover per year for indirect rollovers from IRA to IRA. The IRS extended the 60-day rollover period for distributions taken between February 1, 2020, and May 15, 2020. Investors now have until July 15, 2020, to rollover distributions taken during this period.

Non-spouse beneficiaries are not eligible to roll over a distribution back into an inherited IRA.

 

Q: I am a beneficiary taking distributions on the 5-year rule, how does the 2020 RMD waiver apply?

A: The 5-year period is determined without regard to calendar year 2020.

Example: A beneficiary of an individual who died in 2018 is following the 5-year rule. The 5-year period ends in 2024 instead of 2023.

Note: These changes do not apply to beneficiaries who will be taking distributions based on the 10-year rule.

 

Coronavirus-related distributions (CRDs)

Q: I am impacted by COVID-19. Am I eligible to take a coronavirus-related distribution from my IRA?

A: The Act defines an eligible individual as someone:

  • Who is diagnosed with the virus SARS-CoV-2 or with coronavirus disease (COVID-19) by a test approved by the Centers for Disease Control and Prevention,
  • Whose spouse or dependent (as defined in Code section 152) is diagnosed with such virus or disease, or
  • Who experiences adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus or disease, being unable to work due to lack of child care due to such virus or disease, closing or reducing hours of a business owned or operated by the individual due to such virus or disease, or other factors as determined by the Secretary of the Treasury

You can take a distribution from an IRA at any time. If you need assistance determining if such a distribution would be penalty-free, refer to your financial advisor or tax advisor

 

Q: How do I request a CRD from my IRA?

A: To request a distribution, we can take the request verbally or by completing and submitting the “IRA Single Distribution Request.”

The IRS may provide additional guidance regarding how to report these distributions on your taxes. Refer to your financial advisor or tax advisor for additional information.

 

Q: If I take a CRD from a SIMPLE IRA during the first two years, is the 25% early distribution penalty waived?

A: Yes, CRDs are not subject to an early distribution penalty. If you need assistance determining if you’re eligible to take a CRD, consult your financial advisor or tax advisor.

 

Q: Can I take a CRD from my CB&T 403(b) or governmental 475(b) account?

A: You must check with your employer that a CRD is a distribution event offered by the plan. If so, complete the 403(b)/457(b) Coronavirus-related Distribution Request and submit it to your employer.

If you are otherwise eligible for a distribution, you can request a distribution under that event and still take advantage of the:

  • Waiver of the early distribution penalty
  • Inclusion of income tax over three years
  • Rollover right and possible reversal of tax consequences
  • No required 20% withholding

Q: If I later want to repay a CRD back into my IRA or retirement plan, how much time do I have to repay it?

A: Investors have three years beginning on the day after the date the distribution is made. You can repay the amount distributed or a lesser amount to an IRA or qualified plan that accepts rollovers. The repayment is treated as a rollover. Taxpayers will be able to recover tax previously paid in connection with CRDs that are rolled back into an IRA or plan. We expect the IRS to publish guidance on how to reverse the tax consequences of CRDs that are later rolled back into an IRA or plan.


Investments are not FDIC-insured, nor are they deposits of or guaranteed by a bank or any other entity, so they may lose value.

Investors should carefully consider investment objectives, risks, charges and expenses. This and other important information is contained in the fund prospectuses and summary prospectuses, which can be obtained from a financial professional and should be read carefully before investing. 

All Capital Group trademarks mentioned are owned by The Capital Group Companies, Inc., an affiliated company or fund. All other company and product names mentioned are the property of their respective companies.

This material does not constitute legal or tax advice. Investors should consult with their legal or tax advisors.