Hardship Self Certification

With the new self-certification rules, are there penalties for approving a hardship that is later determined to not be a hardship? Assuming the TPA/Plan Sponsor has no reason to suspect the request doesn't qualify for hardship.

It is my understanding that the old rules required the employer to re-deposit the ineligible hardship.

What I have seen done is the participant is first given a notification to sign stating that they understand the requirements for a hardship withdrawal and have abided by those requirements, and that if it turns out they misrepresented their situation, they would be liable for all damages to the plan and/or employer.  However, I don't believe there are any penalties if the plan administrator follows the self-certification rules in good faith.