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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.
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