Hurrican Sandy Hardship Withdrawal

[Gruegen]

Assuming that a 401(k) plan uses the "safe harbor" method of determining immediate and heavy financial need (and thus requires the participant to obtain a participant loan prior to applying for a hardship withdrawal), does IRS Announcement 2012-44 permits plan sponsors to make Hurricane Sandy Hardship Withdrawals without the participant first applying for a participant loan?

In other words, does the relief in Announcement 2012-44 that a plan sponsor may cease to follow "procedural requirements for plan loans and distributions" mean that Hurricane Sandy Hardship Withdrawals can be processed even though the participant has not obtained a participant loan first?

[Bird]

I don't know, but my take is that "Hurricane Sandy is now a safe harbor reason for a hardship." I don't think it changes the steps needed to qualify.