Skip to main content

You are here

Advertisement

Coronavirus

CARES Act Adoption Defaults

A number of recordkeepers/TPAs are already reaching out to plan sponsors on decisions regarding the optional provisions of the CARES Act, notably COVID-19 related distribution and loan options—but while some are waiting for instructions, others have—at least initially—made some assumptions.      

Recently, several firms reached out to share the results of their canvassing—and while this is certainly a moving target, and subject to change—we have, with their permission—compiled that information into an online table for your reference. This information is current as of May 11.*

For a print-friendly version of this table, please click here.

Recordkeeper/Providers—we’re happy to reflect any applicable changes or additions (email Nevin Adams at [email protected]). 

 

Service Provider
Plan Sponsor Opt-out or Opt-in
Date for Plan Sponsor Decision
Date CARES Act Transactions Available
Fees for Plan Sponsor
Fees for Participants
ADP
Opt-out
4/6
4/7
None
Waiving fees related to COVID-19-related transactions
AIG
Opt-in
N/A
Upon acceptance of the provision by the sponsor
None
Waiving all loan origination fees from April 1-Sept. 30, 2020; does not charge distribution fees
Ameritas Retirement Plans
Opt-in
N/A
Upon acceptance of the provision by the sponsor
None
Currently waiving fees for these transactions; period to be determined
Ascensus
Opt-in
N/A
Upon acceptance of the provision by the sponsor
None
None for COVID-19-related distributions (CRDs) and loans
Bank of America (custom plan doc)
Opt-in
N/A
4/6
TBD
TBD
Bank of America (prototype plan doc)
Opt-out
TBD
4/6
TBD
TBD
Betterment for Business
Opt-in
N/A
Upon acceptance of the provision by the sponsor
None
None
BPAS Opt-out N/A 4/6 No fee to implement CARES Act provisions Standard loan and distribution fees
CUNA Mutual Retirement Solutions
Opt-out
No deadline
3/31
None
None
Empower - Core (<$50 million)
Opt-out
4/3
4/10
Likely yes, determined on a plan by plan basis
None
Empower - Large, Mega, NFP (>$50 million)
Opt-in
4/3
4/6
Likely yes, determined on a plan by plan basis
None
Fidelity - Distributions (CRD)
Opt-out
N/A
4/6
None
No fee for CARES Act distribution and hardships
Fidelity - Loans (CRL)
Opt-in
N/A
TBD
None
TBD
ICMA-RC Opt-in N/A Upon ER  notification No fee COVID-19 loan fees waived. No distribution fees
John Hancock
Opt-in
N/A
4/9
None
Temporarily waiving all hardship fees and waiving all fees associated with CARES Act loans and distributions
J.P. Morgan Opt-out 4/8 (can be modified at any time) 4/13 None None
July Business Services Opt-in N/A Upon acceptance of the provision by the sponsor TBD Waiving distribution fees through June 30th for hardship, ISW and COVID-19-related distributions, and distributions less than $2,000
Lincoln
Opt-in
4/17
TBD
None
None
MassMutual
Opt-in
N/A
4/1
None
None
Milliman
Opt-in
N/A
4/2
Determined on a plan by plan basis
Waiving all COVID-19-related distribution fees
Nationwide
Opt-in
N/A
4/6
None
Fees are waived for any CARES Act withdrawal transactions
Newport
Opt-out
4/5
4/6
Yes; fee for amendment to plan document if contracted in service agreement
Standard transaction fees
OneAmerica Opt-out 4/6 4/7 Fees for COVID-related amendments waived COVID distribution and regular hardship distribution fees waived
PCS Retirement / Aspire
Opt-in
N/A
Upon acceptance of the provision by the sponsor
N/A Will credit recordkeeping fees on both loans and hardship distributions up to $10,000 under the CARES Act back to a qualified individual's account. Credits will be in effect from March 27, 2020 until Dec. 31, 2020; fee credits will cover all tax-qualified employer-sponsored retirement plans that permit such distributions
Pentegra
Opt-out
4/13
As soon as possible
Waiving any amendment fees related to CARES Act provisions
Waiving fees related to coronavirus-related transactions
Principal
Opt-in
N/A
After plan sponsor authorization
None through 9/30/2020
None through 9/30/2020
Prudential
Opt-in
N/A
TBD
None
None
Schwab
Opt-out
4/12
4/15
Waiving all plan amendment fees related to CARES Act provisions
Waiving all loan and distribution fees from 4/15/20 through 12/31/20
Securian Financial
Opt-out
N/A
4/15
None
None
Security Benefit Opt-out N/A 4/6 Waiving plan  amendment fees related to CARES Act provisions Waiving fees for distributions and loans under the CARES Act
The Standard
Opt-out
4/3
4/13
No amendment fees through Aug. 31, 2020
Waiving distribution and loan origination fees for COVID-affected participants through Aug. 31, 2020
T. Rowe Price - Distributions (CRD)
Opt-in
No decision date
First distribution available 4/13 for Institutional market; 4/6 for Core market
None
No fees for duration of distribution (12/31/20)
T. Rowe Price - Loans (CRL)
Opt-in
No decision date
First distribution available approx. 5/8 for Institutional market; 4/6 for Core market
None
No fees for participant (for Institutional market, loan initiation fee will be deducted but credited back to participant in Q4, which is the same process as standard loans; loan available through 9/23/20 which is 180 days after CARES Act was signed. For Core market, fees will be waived starting 4/13 and credited for loans taken from 4/6-4/13)
TIAA
Opt-in
Opted-in plans using TIAA documents 3/28; remaining plans opted-in 4/6, unless otherwise specified
CARES transactions available beginning 3/28 for both CRDs and loans
None
No fees for CRDs and standard loan fees
Transamerica
Opt-out for volume submitter clients; opt-in for IDP clients
4/17 for opt-out, but plans can elect earlier opt-in date
Early adopters live as of 4/6
None
No participant transaction fees for CRDs only
Vanguard
Opt-in
N/A
4/1
TBD
None
Voya
Opt-in
N/A
Ready now, 5 days post LOD receipt
Likely no, with the exception of changing plan design in plans >$75m
Credit will be applied to refund fee
Wells Fargo
Opt-in
N/A
Week of 4/6
None
None

*IMPORTANT NOTE: Some of the defaults listed may have changed since their initial communications with plan sponsors. While we understand these to be the most current defaults, please double-check with your provider. Additionally, there may well be different defaults for individually drafted versus prototype plans.

Advertisement