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applicable and vary by state. The otherwise applicable early withdrawal penalty of 10% is not
applicable for a CRD.

13. How is a distribution under CARES Act coded on the 1099R form?
It will be coded as a normal in-service withdrawal on the 1099R. When the participant files
their 1040 they have to indicate that it was an in-service withdrawal under the CARES ACT.

14. Can a qualified participant take both a CRD and loan at the new maximum
amounts?

There are no restrictions on the ability to take both a loan and distribution so long as the plan
has elected to add both of these optional provisions, and the plan setup allows for loans. A
qualified participant may take up to the maximum $100,000 CRD and up to the maximum
$100,000 loan if they qualify and the account balance supports both transaction amounts.

15. Will MassMutual be waiving any participant transaction fees as a result of the
CARES Act?
Yes, MassMutual will temporarily waive the following fees:
 CARES related In-service Withdrawal (CRDs) distributions
 All Loan initiation fees (loan maintenance fees still apply)
 All Hardship distribution fees (both check fee and approval fee, if applicable)
 If the plan has TPA loan or distribution fees deducted from participant accounts,
MassMutual will reimburse those fees to the participant account and pay the fee to the
TPA unless the TPA has also waived their fees

16. When will the CRDs or CARES Act Loans have to be taken by?
CRD provisions apply to distributions to Qualified Individuals made on or after January 1, 2020,
and no later than December 31, 2020. Loan repayments for Qualified Individuals, due
between March 27, 2020, and December 31, 2020, may be delayed for one year. Qualified
Individuals may, during the 180-day period beginning on March 27, 2020, take a loan from a
qualified employer plan in an amount up to the lesser of $100,000 or the participant’s full
vested account balance.

P a g e | 7 | RS-49007-00
This document is intended for Plan Sponsor and Third-Party Administrator use only. Not intended for Participant
use.
insurance companies
Massachusetts Mutual Life Insurance Company (MassMutual), Springfield, MA 01111-0001,and it affiliated US