, Q&A-15 (rev. September 19, 2020). The IRS stated that employees who were rehired by the end of the review period would not generally be considered to have experienced an employer-initiated severance when evaluating a partial plan termination. If there is a partial plan termination, affected participants (those who experienced an employer-initiated severance) must be 100% vested.
E-signatures and Remote Notary Guidance from IRS (Retirement) In response to the COVID-19 pandemic, the IRS issued temporary relief from the physical presence requirement in Notice 2020-42. Retirement plans often require participant elections and spousal consents to be notarized or witnessed by a plan representative. The notice allows for remote notarization in states that permit them. Plan representatives may also witness a signature remotely using certain safeguards, as specified in the notice. This relief is available from January 1, 2020, through December 31, 2020, so, absent an IRS extension, the standard physical presence requirements will resume on January 1, 2021.