Five Recordkeeping Considerations Related to the CARES Act

The CARES Act provides plan sponsors the opportunity to provide access to retirement funds for individuals impacted by the coronavirus (COVID-19).  These are optional provisions, so you are not required to offer them in your plan.  As you review your options, below are a few items to work through with your recordkeeper and committee.

  • Review your recordkeeper’s ability to administer the new CARES Act provisions and timing of their availability.
  • Contact your recordkeeper to understand if they are negatively enrolling plans to include these provisions. If you do not want the provisions added to your plan right now or need additional time to review the provisions, notify them of your decision to ‘opt out.’
  • Determine if any negative enrollment decisions cover all provisions of the CARES Act or only a portion. Some recordkeepers are negatively enrolling all provisions, while others are only negatively enrolling the early withdrawal provisions.
  • If you have an investment committee, review the provisions and determine whether a formal committee review is needed to adopt the provisions. Document any meetings or votes related to this topic.
  • If you elect to offer the withdrawal options, contact your recordkeeper to understand if they plan to communicate this to participants or if they have materials you can use to communicate.

You can download a PDF of these five considerations by clicking the button below.

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Have questions about the provisions? Please contact a Multnomah Group consultant.



Multnomah Group is a registered investment adviser, registered with the Securities and Exchange Commission. Any information contained herein or on Multnomah Group’s website is provided for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and, unless otherwise stated, are not guaranteed. Multnomah Group does not provide legal or tax advice.

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