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Question 1: Plan is a multiemployer DC plan classified as a profit-sharing plan. Employee contributions are not permitted. All contributions are from employers only as dictated by a Collective Bargaining Agreement. Can that plan allow hardship withdrawals?

Question 2: Assume that the Plan can add hardship withdrawals. It adds the safe-harbor hardship withdrawal language effective July 1, 2016. Are participants able to access their entire account balances come July 1? Or is it only on money that is contributed on or after July 1, 2016?

Thanks.

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