Hardships: safe-harbor v facts & circumstances question???

[Guest Philip Simpkins]

The way I am reading Reg 1.401(k)-1(d)(2)(iii) and/or (iv) is that a safe-harbor plan participant can have a $1,000,000 CD and still not be excluded from applying for and receiving a hardship withdrawal. It appears to me that only the facts and circumstances plan participants are required to satisify the need from other sources that are reasonably available outside the plan. Can that be true? Thanks in advance.

[MWeddell]

Yes, this is true if the plan is using the safe harbor standard for the resources test (not just for the events test).