Yes, even if a retirement plan doesn’t specifically make CRDs available, provided an individual meets the qualification requirements outlined in the CARES Act (see Who is eligible to take a coronavirus-related distribution?) , the favorable tax treatment for CRDs is still available; specifically:
- waiver of the 10% premature withdrawal penalty
- ability to pay income tax over a three-year period
- option to recontribute the CRD amount to a retirement plan or an IRA within three years
Practically, if a plan didn’t specifically authorize CRDs, this option is only available to those participants and beneficiaries who have a distributable event, such as termination of employment, in-service distribution, hardship, death, or disability. Note that if the plan doesn’t allow coronavirus-related distributions, the disbursed amount will be subject to a 20% mandatory withholding at the time of the distribution.