By Ian Berger, JD
IRA Analyst



The CARES Act includes a waiver of RMDs for this year from company savings plans and IRAs.

I am in the minority of retirees that took my 2020 RMD in January 2020, withheld 20% for taxes and am now finding out that I “missed” the 60-day rollover window to put the money back into my IRA by no fault of mine. Since RMDs are essentially eliminated for 2020, why can’t I put the entire amount into my Roth IRA?

Assuming I can do that “conversion,” is there a time limit to do that?

Thank you for considering my dilemma.



Hi Ram,

Unfortunately, conversions to a Roth IRA are subject to the same 60-day rollover rule that applies to rolling over waived RMDs back to an IRA. The IRS has extended that 60-day deadline (to July 15, 2020), but only for RMDs made in February 2020 or later.

However, all may not be lost. It is possible the IRS may expand its relief to cover distributions made in January 2020. Stay tuned.


I am over 65 and retired. Can I borrow up to the $100,000 from my Roth IRA and redeposit it within the next 3 years?  I know it wouldn’t be taxed because I’ve had it for more than 5 years and I’m of retirement age. I just need the money now, and I would be able to replace it if it’s allowed.

Thank you. I haven’t seen this issue addressed anywhere.


Since you are over age 59 ½ and established a Roth account at least five years ago, you can always take a tax-free distribution from your Roth IRA. Your ability to repay the distribution within 3 years depends on whether you are a considered a “qualified individual” under the CARES Act.

Not everyone is a “qualified individual.” You meet that definition only if:
·      you have been diagnosed with SARS-CoV-2 or COVID-19 by a test approved by the CDC;

·      your spouse or dependent has been diagnosed with the virus; or

·      you have suffered “adverse financial consequences” due to the virus as a result of:

Ø  being quarantined; being furloughed or laid off; or having work hours reduced;

Ø  being unable to work due to lack of child care; or

Ø  closing or reducing hours of a business you own or operate.