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As the impact of the Coronavirus intensifies, retirement plan advisors and other industry stakeholders are seeking reliable information about business continuity regarding their firms and the potential effects on plan administration and client services.

This resource page on the Coronavirus pandemic’s impact on plan advisors and others in the retirement industry is intended to help you:

  • scan the policies and procedures that TPAs and recordkeepers have adopted in response to the CARES Act's optional provisions;
  • find online commentary from industry thought leaders on critical business continuity issues;
  • track our news coverage of the pandemic;
  • access the American Retirement Association’s pandemic-related advocacy efforts in Washington, DC;
  • access regulatory and other guidance from federal agencies; and
  • quickly find pertinent legislation that has been enacted or is being considered by Congress.

You will find links to ARA communications to Congress, Treasury, the IRS and the DOL; NAPA’s news coverage; legislation on Capitol Hill; regulatory and other guidance from federal agencies; and recommended online commentary for plan advisors and plan sponsors.

Last updated March 21, 2022

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—but while some are waiting for instructions, others have—at least initially—made some assumptions. While this information is subject to change, we have compiled it in an online table for your reference.

CARES Act Administrative Q&As

As part of a series of recent webcasts, we have received a large number of questions from our members regarding key operational and administrative aspects of the Coronavirus Aid, Relief and Economic Security (CARES) Act. As we continue to work with regulators to achieve clarity and receive guidance on this legislation, visit our CARES Act Administrative Q&As page for our most current understanding of the various issues. We have organized the questions and answers into several broad categories.


Visit our CARES Act FAQs page to stay informed about various questions and answers concerning key provisions the ARA believes will positively impact retirement plan participants and plan sponsors. The FAQs are arranged by topic.

ARA Advocacy

The American Retirement Association strongly supports legislation and regulatory guidance that provides immediate relief to retirement plan sponsors, participants and retirees in the wake of the Coronavirus. Letters from the ARA to Congress and federal agencies are provided below.  

ARA Request to EBSA for Disclosure and Notice Relief (March 30, 2020)

ARA Letter to Treasury on DC Plan Funding Relief and More (March 24, 2020)

Industry Trade Letter Urging Retirement Plan Relief (March 20, 2020)

ARA Proposal for DC Plan Funding Relief (March 19, 2020)

ARA Letter to Departments of Labor and Treasury (March 16, 2020)

ARA Letter to IRS Regarding 403(b) Plan Remedial Amendment Period (March 16, 2020)

ARA Retirement Plan Legislative Relief Proposal (March 13, 2020)

NAPA News Coverage

Browse our news posts and commentary concerning the Coronavirus pandemic, including ARA recommendations for addressing the challenges, and the latest legislative and regulatory developments affecting retirement plans.


Consolidated Appropriations Act, 2021 (H.R. 133 / P.L. 116-260) (Dec. 27, 2020)

Paycheck Protection Program Flexibility Act  (H.R. 7010 / P.L. 116-142) (June 5, 2020)

Paycheck Protection Program and Health Care Enhancement Act (H.R. 266) (April 24, 2020)

Joint Tax Committee Description of CARES Act Tax Provisions (April 22, 2020)

Coronavirus Aid, Relief, and Economic Security (CARES) Act (Enrolled version of H.R. 748, as approved by the House and Senate, March 27, 2020)

Families First Coronavirus Response Act (H.R. 6201/P.L. 116-127). This law provides paid sick leave and free Coronavirus testing, expands food assistance and unemployment benefits, and requires employers to provide additional protections for health care workers.

Regulatory Guidance

EBSA Disaster Relief Notice 2021-01: Guidance on Continuation of Relief for Employee Benefit Plans and Plan Participants and Beneficiaries Due to the COVID-19 (Novel Coronavirus) Outbreak (March 1, 2021)

SBA and Treasury Announce Simpler PPP Loan Forgiveness Application (Oct. 8, 2020)

PBGC Expands Flexibility for Variable-Rate Premium Filers (Sept. 21, 2020)

Select COVID-19 Compliance Risks and Considerations for Broker-Dealers and Investment Advisers (SEC Risk Alert, Aug. 12, 2020) 

IRS Notice 2020-52 (2020 mid-year reductions of matching contributions, June 29, 2020)

IRS Notice 2020-51 (waiver of 2020 RMDs, June 23, 2020)

IRS Notice 2020-50 (extension of COVID-19 relief, safe harbors; June 19, 2020)

IRS Notice 2020-42 (spousal consent via remote means, June 3, 2020)

IRS Notice 2020-35 (employment tax and other relief, May 28, 2020)

IRS Q&As on CARES Act (updated Oct. 22, 2021)

IRS Notice 2020-32 (deductibility of PPP-related expenses, April 30, 2020)

EBSA Disaster Relief Notice 2020-01 (Guidance and Relief for Employee Benefit Plans Due to the COVID-19 Outbreak, April 28, 2020)

EBSA COVID-19 FAQs for Participants and Beneficiaries (April 28, 2020)

SEC FAQs (addresses developments in relation to the COVID-19 pandemic; updated April 27, 2020)

IRS Notice 2020-23 (extension of additional tax-filing deadlines)

IRS Extends Deadlines for 403(b) and Pre-Approved DB Plans (March 27, 2020)

IRS Filing and Payment Deadline Q&As (includes questions about IRAs and workplace-based retirement plans (March 24, 2020)

IRS Notice 2020-18 (extension of tax-filing deadline)

IRS Notice 2020-15 (High Deductible Health Plans and Expenses Related to COVID-19)

Practice Pointers

Stay the Course (PGIM, February 2022)

Envisioning the New Normal: Real Estate & Technology (Goodwin Procter LLP)

3 Proactive Conversations You Need to Have with Plan Sponsor Clients (Fiduciary Benchmarks, June 9, 2020)

Considerations for Return to Office (SIFMA, May 2020)

Companies That Suspended Their 401(k) Match (Center for Retirement Rs=esearch, May 2020)

Is Now the Time for a Roth Conversion? (Cammack Retirement, May 14, 2020)

How RIAs Can Determine if They Need to Disclose PPP Loans on ADV Part 2A (, April 30, 2020)

Should Financial Advisors Accept (and Disclose) PPP Loans? (, April 23, 2020)

Fixing Unwanted RMDs Taken Before the CARES Act Waiver of 2020 RMDs ( April 22, 2020)

Equipment to Create the Ideal Home Videoconferencing Setup—What FAs Should Use (, April 16, 2020)

Hard Choices: Making Key Business Decisions to Preserve Culture in Times of Crisis (, April 13, 2020)

ERISA Litigation Lessons for Today from the Great Recession (The Wagner Law Group, April 7, 2020)

Quickly Maximizing PPP's Forgiveable Loan Opportunity for FAs (

COVID-19 Plan Document And Administration FAQs (ASC)

Chances Are, Your Business Continuity Plan Did Not Fully Address This... (The Wagner Law Group, March 30, 2020)

Coronavirus Update (NAPA webcast PowerPoint presentation, March 30, 2020)

Analyzing the CARES Act: From Rebate Checks to Small Business Relief (Jeffrey Levine,, March 27, 2020)

Letters of Support to Clients (Bob Veres, March 23, 2020)

Pivoting Quickly to a “Work From Home” Model: What Advisory Firms Need to Know (Matt Sonnen, Nerd’s Eye View, March 23, 2020)

Rapid Shift to Working from Home Increases Cybersecurity Risk (Callan, March 20, 2020)

Being Proactive with Your Operations During an Emergency (Charesse J. Hagan LLC, March 20, 2020)

Employee Benefits Issues to Consider Before Deciding to Furlough or Terminate Employees During the COVID-19 Pandemic (JacksonLewis, March 19, 2020)

ERISA Considerations for Investment Managers—COVID-19 and Volatile Markets (Schulte Roth & Zabel, March 19, 2020)

Plan Sponsor Purview

A Chronology of COVID-19 Relief for ERISA Plans (Verrill, Aug. 10, 2020)

Do Employers Need COVID-18 Waivers? (Wagner Law Group, July 30, 2020)

IRS Still CARES—Suspension or Reduction of Safe Harbor Contributions for 2020 (Ferenczy Benefits Law Center, June 30, 2020)

Administering CARES Act's Waiver of 2020 RMDs from DC Plans (Mercer, June 25, 2020)

What Happens to Participants' COVID-Related Distributions When an Employer Chooses Not to Treat Them as Such? (Bob Toth, June 22, 2020)

DC Plan Nondiscrimination Testing in the Age of COVID-19 (Vanguard, May 2020)

Planning to Move from Survive to Thrive with Company Retirement Plans (MassMutual, May 21, 2020)

Six Considerations for Plan Fiduciaries During the COVID-19 Pandemic (Morgan Lewis, May 21, 2020)

COVID-19 and ESOP Distribution Policies (Krieg DeVault, May 19, 2020)

COVID-19 Joint Agency Relief, Part 2 (Faegre Drinker, May 19, 2020)

COVID-19 Joint Agency Relief, Part 1 (Faegre Drinker, May 13, 2020)

Navigating Market Crises: Insights and Recommendations (Cambridge Associates, May 2020)

CARES Act Loan Provision: The 'Fly in the Ointment' (Cammack Retirement, April 23, 2020)

Reducing or Suspending Contributions to a 401(k) or 403(b) Plan (Faegre Drinker, March 23, 2020)

ERISA Fiduciary Insurance and Plan Sponsors' COVID-Related Cyberliability (Ackerman LLP, April 21, 2020)

Considerations for Obtaining Spousal Consent at a (Remote) Social Distance (Morgan Lewis, April 21, 2020)

Should We Include Government-Related Coronavirus PTO When Calculating Company Contributions? (DWC, April 21, 2020)

What Plan Sponsors Should Know about CARES (Ilene Ferenczy for CUNA Mutual, April 21, 2020)

The Fiduciary Angle to the COVID Certification Because of Spousal Employment Loss (Bob Toth, April 16, 2020)

Enforcing the $100,000 Distribution Limit on Multiple Plans in the Same Controlled Group (Morgan Lewis, April 16, 2020)

A Checklist for Sponsors to Consider Before Adopting Retirement Plan Provisions of the CARES Act (Husch Blackwell, April 16, 2020)

CARES Act Plan Sponsor Survey (PSCA, April 14, 2020)

The CARES Act: Do We Have To? (Ferenczy Benefits Law Center, April 14, 2020)

Special Distributions to Qualified Participants (, April 13, 2020)

COVID-19 Executive Compensation Q&As: Incentive Plans and NQDC (Pepper Hamiltion LLP, April 13, 2020)

Are Your TDFs a Prudent Investment? COVID-19 Puts a Spotlight on Fiduciary Choices (Cohen & Buckmann, PC, April 2020)

Before You Adopt Those COVID-19 Loan and Distribution Provisions... (Mike Webb, Cammack, April 9, 2020)

Sample Employee Notice for Coronavirus-Related Retirement Distributions (Jones Walker, April 7, 2020)

The Enhanced Loan Provision for Qualified Participants (, April 6, 2020)

ERISA Fiduciary Best Practices and Prudence in the COVID-19 Environment (Mayer Brown, April 2, 2020)

COVID-19 Webcast Q&As (Derrin Watson, April 2, 2020)

Substantial Workforce Cuts and Partial DC Plan Terminations (Callan, April 2, 2020)

CARE Act Suspension of Loan Repayments: Is it the Employer's or the Participant's Choice? (Bob Toth, April 3, 2020)

CARES Act Retirement Provisions FAQ (for individuals) (Sen. Chuck Grassley, April 2, 2020)

CARES Act Loan Payment Suspension Rules Take an Unusual Approach (Bob Toth, March 31, 2020)

The Coronavirus Pandemic: What Plan Sponsors Should Do (Fred Reish, March 31, 2020)

Treatment of COVID-19 Sick and Leave Pay Under Your Retirement Plan (Warner Norcross + Judd, March 31, 2020)

Q&As: Impact of the CARES Act on Executive Compensation (McDermott Will & Emery, March 30, 2020)

Federal Government CARES (Act) About ESOPs (Kaufman & Canoles, March 2020)

CARES Act: Plan Sponsor Action Items (Wilkins Finston Friedman, March 30, 2020)

Minimizing the Risk of ERISA Litigation in a Turbulent Economic Climate (Proskauer, March 30, 2020)

Execvutive Compensation Limits in CARES Act Raise Questions (Troutman Sanders, March 27, 2020)

COVID-19 FAQs (McDermott Will & Emery, March 2020)

COVID-19 and Executive Benefits (Lockton, March 2020)

Impact of the Historic CARES Act on Retirement Plans—and Action Items for Plan Sponsors (Trucker Huss, March 2020)

Coronavirus Relief from Congress (Ferenczy Benefits Law Center, March 27, 2020)

The CARES Act: Relief for Small Businesses (The Wagner Law Group, March 27, 2020)

Planning and Implementing a Temporary Layoff in the Age of COVID-19 (The Wagner Law Group, March 27, 2020)

How Do We Stop Our Discretionary Matching Contribution? (DWC, March 26, 20200

How DC Plans Should Prepare for Missed Loan Repayments (Callan, March 25, 2020)

COVID-19 Impact on Executive Compensation (Leave of Absence) (Proskauer, March 24, 2020)

COVID-19 Layoffs—Partial Retirement Plan Termination? (TRI-AD, March 24, 2020)

Updates on Hardship Withdrawals Amid the COVID-19 Crisis (Morgan Lewis, March 2020)

COVID-19 Retirement Plan Q&As for Employers (Troutman, March 24, 2020))

Suspending or Reducing Safe Harbor Contributions (The Wagner Law Group, March 24, 2020)

Hardship Withdrawals Amid the COVID-19 Crisis (MorganLewis, March 21, 2020)

The Families First Coronavirus Response Act (The Wagner Law Group, March 20, 2020)

COVID-19 and Withdrawal Liability (JacksonLewis, March 20, 2020)

Unprecedented Times Can Call for Precedented Measures: Exploring Effective Ways to Reduce Retirement Plan Expenses During Uncertain Times (Vestwell, March 19, 2020)

Employee Benefits Questions and Answers Related to COVID-19 (Hanson Bridgett, March 19, 2020)

Coronavirus Check-Up for Retirement Plans (Groom Law Group, March 19, 2020)

FAQs: Can I Suspend the Safe Harbor Contribution? (Retirement Management Services, March 19, 2020)

Employer Actions for 401(k) Plans Sickened by Coronavirus (Dickinson Wright, March 19, 2020)

Employer Responses to COVID-19: Suspending Employer 401(k) Contributions (Cohen & Buckmann, P.C., March 19, 2020

Benefits Guidance in the Time of COVID-19: Monitoring Retirement Plan Investments and Participant Communications (Epstein Becker Green, March 18, 2020)