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About records retention, there is no one uniform answer that is right for every service provider. Here’s a list of some questions I ask when I design a TPA’s, recordkeeper’s, or similar service provider’s records-retention/destruction plan: How often does it happen that a client’s question, worry, or request, or the business’ response, is in e-mail and is not fully described in other writings? Does the business want to be ready to save a client from the client’s failure to keep a record it ought to have kept? Does the business or an affiliate sometimes offer services as a § 3(16) administrator? a plan’s trustee? an investment manager? Does the business or an affiliate sometimes offer banking services? insurance-agency services? securities broker-dealer services? commodities dealer services? investment-adviser services? Has the business made any agreement with another service provider or a financial-services business? Read each of those agreements to find records-retention obligations. Does any record about a client ever get used in evaluating an employee’s job performance? In how many States are the clients located? Considering the business’ usual forms of service agreements, do they always, often, seldom, or never specify which State’s law governs the agreement? Considering the business’ usual forms of service agreements, do they always, often, seldom, or never specify a time limit on claims against the service provider? How often does the business face subpoena and other document-production demands? Does the business charge a client expenses, fees, or both for a document production?

Talk about micromanagement from the TPA.... tell them to take a pill and relax. If the participant has a need to the maximum and has paperwork to support it, they are going to get a check for the maximum. We get participants asking the hardship availability more often than you think. Look on the bright side, in less than 6 months it won't matter because the basis equation is out the door.

Yeah, but if it's payroll-copmuted match, you have to do it quarterly - should be in the doc to that extent.

The plan admin is tarred and feathered... ...Unless you make the participants whole by allocating lost earnings. EPCRS principles of correction would apply. You do not lose SH status if you correct.

Please let me know if I can help you find a new TPA.

Our website for participants shows the amount available went the participant logs in and goes to the hardship withdrawal tab.

Effen right you are!

I believe expanding/liberalizing eligibility is one of the permissible mid-year amendments for safe harbor plans.