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Posted

I know the regs say for a safe harbor hardship, all distributions and loans must be taken first. Someone told me that if a loan would be considered a burden itself, then it doesn't have to be taken and the participant can go ahead and take the h'ship without first having a loan.

Is this true? Is it written anywhere?

Your thoughts are appreciated as always.

Remember: two wrongs don't make a right, but three rights make a left.

Posted

The boards seem to be reformatting cites, so I'll try a non-standard representation and see if it too gets mangled:

1.401(k)-1[d][2][[iii][[4]

  • 3 weeks later...
Posted

1.401(k)-1[d][2][[iii][[4] states that you can bypass the loan IF "the effect would be to increase the amount of the need."

Would that be limited to circumstances where taking a plan loan would increase the specific hardship being applied for? Or would that fact that paying back a plan loan would be a financial burden to the participant be enough to bypass taking the loan and move right to a hardship distribution?

Posted

A good argument can be made for the latter, if it is indeed the case.

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