There are exceptions. Actions that re not coronavirus-related include:
* Corrective distributions of elective deferrals and employee contributions that are returned to the employee (together with the income allocable thereto) in order to comply with the § 415 limitations, excess elective deferrals under § 402(g), excess contributions under § 401(k), and excess aggregate contributions under § 401(m);
* loans that are treated as deemed distributions pursuant to § 72(p);
* dividends paid on applicable employer securities under § 404(k); the costs of current life insurance protection;
* prohibited allocations that are treated as deemed distributions pursuant to § 409(p);
* distributions that are permissible withdrawals from an eligible automatic contribution arrangement within the meaning of § 414(w);
* and distributions of premiums for accident or health insurance under § 1.402(a)-1(e)(1)(i).
The guidance also clarifies that employers can choose whether to implement these coronavirus-related distribution and loan rules and notes that qualified individuals can claim the tax benefits of coronavirus-related distribution rules even if plan provisions aren't changed.