CARES Act Frequently Asked Questions
1. What do we need to do to enable CARES Act distribution and loan provisions in our plan?
If your plan already allows for loans, then no action is required on your part. BPAS will automatically update the distribution and loan options within your plan to include the CARES Act provisions.
If your plan does not include a loan provision currently, BPAS will automatically update the distribution options within your plan to include the CARES Act provisions. If you wish to add the CARES Act loan provision, please contact your BPAS representative to complete the required loan elections. We will make every effort to enable loan functionality online as soon as possible. Please note, however, that to comply with current fee disclosure requirements, it will not be enabled for at least 45 days after the request is made.
2. If we do not currently allow for loans, can we implement only these CARES Act loans?
Yes. For plans that do not currently have a loan provision, reach out to your BPAS representative to complete an election to add the CARES Act loan feature.
3. What sources are available for CARES Act loans and distributions?
All contribution types, except money purchase funds, are included regardless of the participant’s age or service.
4. How will participants request a CARES Act distribution or loan?
Participants will have access to the Coronavirus-Related Distribution Form by logging into their account at bpas.com and accessing the Resource Center/Administrative Forms.
Participants may model and request a loan by logging into their account at bpas.com and selecting Transactions/ Loan Modeling and Requests. We are currently updating our system to reflect the expanded limits and will reflect the new amounts available to the participant. We anticipate this update to be completed this week.
5. What proof is required to certify that a participant is a “qualified individual” and entitled to the provisions?
The CARES Act allows plan sponsors to rely on participant self-certifications that they are qualified individuals and eligible for coronavirus-related distributions and loans. We have created a Coronavirus-Related Distribution Form and included a section for self-certification in our loan documentation.
6. What do we need from a participant to stop withholding current loan payments?
Participants must certify they are qualified individuals and are eligible to defer loan payments. We are finalizing the procedure for participants to complete this self-certification on our website. However, qualified individuals may request that their loan payments be stopped immediately, even before completing the certification.
Loan payments that are due between March 27 and December 31, 2020 may be delayed. However, participants will be required to resume loan payments beginning in January 2021. Participant loans will be reamortized as of January 2021 to include delayed payments from 2020, any accrued interest, and an additional 12-month extension to the original loan payoff date.
7. Where can participants find more information about the CARES Act?
Please direct participants to pec.bpas.com. We will update it frequently with additional information about the CARES Act, including steps to request a loan, distribution, or loan deferral.