CitiBank used to have a jingle in their ads in the 1980s that “Citi never sleeps, CitiBank”. While most of us are hunkered down thanks to this Coronavirus epidemic, it doesn’t mean that as the plan sponsor, you can just fall asleep.
As a plan sponsor, you still have to exercise your fiduciary duty prudently. You still have to deposit salary deferrals promptly and you have to make sure that plan sponsors are informed as they are legally required.
As long as we don’t receive guidance from the Internal Revenue Service or Department of Labor top the contrary, to quote Bill Belichick: “do your job.”