What if a distribution was taken prior to enactment of the CARES Act? Can it be treated as a coronavirus-related distribution?

Yes, because this provision applies to distributions made back to January 1, 2020, individuals who have already taken will be exempt from the 10% early withdrawal penalty provided the coronavirus-related distribution requirements are satisfied( i.e., the individual meets the definition of a “qualified individual” and the aggregate amount of coronavirus-related distribution withdrawal doesn’t exceed $100,000). 

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Cetera Retirement Plan Specialists is a third-party administrator and may not offer tax, legal or investment advice. Plan sponsors should consult their own tax, legal or investment professionals.