When the Coronavirus Aid, Relief and Economic Security (CARES) Act was signed into law on March 27, 2020, it provided a waiver for 2020 Required Minimum Distributions (RMDs) from IRAs and defined contribution retirement plans as outlined in our March 31 CARES Act brief.
For investors who already took a 2020 RMD, the IRS recently issued new guidance that provides rollover relief for these distributions. According to IRS Notice 2020-51, individuals who took an RMD at any time in 2020 have until August 31, 2020 to roll the distribution back into any IRA or qualified retirement plan account with no penalties if they desire to do so. In addition, this action will not count toward the one rollover per twelve months limitation that exists for certain IRAs.
The IRS Notice also outlines how 401(k), 403(b) and 457(b) plan documents should be amended by plan administrators for the 2020 RMD waiver and rollover relief provisions and provides a pre-approved sample amendment for this purpose.