CVD rollover

I have many clients, under 59.5 that qualify, but do not need the 100k. But they would like to take the 100k from the 401k and either Roth convert it, or just put into IRA with other investment choices.

Can they do this?



Appears OK per the CARES Act provisions if they qualify for a CV distribution, however it is not clear whether qualified plans are required to provide these distributions. 

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