The ‘‘Coronavirus Aid, Relief, and Economic Security Act’’, referred to as the ‘‘CARES Act’’, which was signed into law on Friday, March 27th, includes relief for defined benefit plan “minimum funding requirements”. Plan Year 2019 required contributions due in 2020, and Plan Year 2020 quarterly installment contributions due in 2020, may be deferred until January 1, 2021, at which time the contributions must be paid with interest. Please note that for certain contributions, such as funding to complete a plan termination or contribution obligations under a collective bargaining agreement, it is not clear whether this special timing rule applies; IRS guidance (if or when issued) may be helpful, or the advice of legal counsel may be necessary for these circumstances. ACSI (www.acsi-ny.com or mbrand@acsi-ny.com) is available if you have retirement plan questions.
