The proposed rule remains a proposed rule.
Analyzing all comments, writing explanations about how an agency was or wasn’t persuaded to revise the proposed rule, and other work required under the Administrative Procedure Act and other Federal laws is, even for experienced agency lawyers, difficult and time-consuming work.
The November 14, 2018 notice of proposed rulemaking about hardship distributions set January 14, 2019 as the due date for comments. Because the Treasury department then had a funding lapse through January 25, there have been only ten business days available for work on the comments. (And for the three lawyers assigned, this rulemaking is not the only project.)