I have a client that has failed the ADP test and will need to take a refund. However, last April he took a hardship distribution which wiped out most of his deferral account and he now does not have enough money to process his refund. What course of action would we need to take? Technically the deferrals are no longer in his account and he did not roll it over so basically we have the same result except for the distribution code and early withdrawal penalty. He was not 59.5 when he took his hardship. Any help is much appreciated.
