We are not quite 60 days past the signing of the CARES Act, legislation that, depending on plan adoption decisions, significantly expanded participant access to their retirement accounts.  Are you seeing an uptick in that activity?

Early information from recordkeepers suggests that withdrawal and loan rates in the first quarter (pre-CARES, and mostly pre-pandemic) were, if anything, a bit lower than normal.  Early surveys (including one by sister association the Plan Sponsor Council of America (PSCA)) suggested that many plan sponsors were taking a thoughtful approach to adoption of the expanded withdrawal and loan provisions.   

Realizing that a wide range of factors – geography, industry, exposure to COVID, etc. – not to mention the availability of the new withdrawal and loan provisions - can impact the volume of pre-retirement distributions, we’re curious as to if you are seeing any change in loan and withdrawal volumes post-CARES (adopted on or after 3/27/20).

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* 1. Have your plan sponsor clients adopted the expanded COVID-19 withdrawal provisions (Coronavirus-related withdrawals, or CRW)? ?

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* 2. Generally speaking, among the plans you work with that have adopted the new COVID-19 withdrawal option, how has the volume of CRW withdrawals compared with normal hardship withdrawal volumes?

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* 3. Generally speaking, among the plans that have adopted CRW, what level of use have you/they experienced (remember to exclude regular hardship withdrawals, in-service withdrawals and post-separation withdrawals)?

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* 4. Have your plan sponsor clients adopted the expanded COVID-19 loan provisions?

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* 5. Among the plans that have adopted the new COVID-19 loan option, have you/they noticed an increase in loan requests?

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* 6. Where are most of the clients who have adopted the COVID provisions located?

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* 7. Comments about the adoption of these provisions, take-up rate(s) under these provisions, or how you see those rates changing in the weeks ahead?

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* 8. What is your role working with retirement plans?

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* 9. What size plans do you PRIMARILY work with?

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* 10. All responses are confidential, of course - but if you'd be open to the potential for a followup email/call, please provide contact information.

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