No relief was provided for non-qualified retirement plan distribution rules in the CARES Act. However, on June 19, 2020 in Notice 2020-50, the IRS offered limited relief.
Generally, non-qualified deferred compensation plan deferral elections must be made by the end of the taxable year before the year for which the deferral is made (i.e., 2020 elections were made by end of the 2019 calendar year). Thus, many participants whose financial circumstances changed were locked into 2020 compensation deferral elections. The IRS guidance allowed cancellation of these elections.