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Posted

Many of my clients, including me,  being in Florida took mild to substantial damage due to Hurricane Irma. Two questions:

1. I have a client located in Brevard County, Florida. Can any one determine if this client would qualify for special relief under Announcement 2017-13 and anything else? 

2. Under this announcement, even though special relief is being granted for qualifying for a hardship distribution, does anyone have an opinion on whether or not they would still be required to take a loan from the plan before the hardship distribution could be made?

Thanks for the help - Rick 

Posted

FEMA disaster link  IRS grants relief to counties identified for individual assistance by FEMA.  As of right now, Brevard is not on the list, but neither is Polk county and they got hit really hard so additional counties will have to be added.

Also, under 2017-13, a participant could request a hardship distribution  if they or a lineal ascendant or descendant, dependent, or spouse had their principal residence or place of employment in one of the identified counties.

You could easily make the argument that a loan would would be counterproductive or add to the hardship, so no, I don't think you need to worry about exhausting loans first.  

 

 

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