Implementation of New Hardship Rules

Is anybody going to apply the new hardship rules January 1, 2019 or are you waiting for IRS guidance?   Our relationship managers are pushing to implement January 1 and our document provider (FTW) is not going to update the document until the IRS issues guidance.     Fidelity is implementing January 1.    What are other document providers like ASC, R.A., etc. doing?    Thank you

I suspect FT will have something issued before the end of the year anyway, so probably a moot point, but rather than issue an amendment now that might have to be change slightly they are waiting.

I believe the guidance we are waiting on is for situations such as someone who takes a hardship is Dec is suspended for 6 months from deferring. now, when that requirement 'disappears' at the start of the new year can this individual start deferring again immediately?

I believe FIS (Relius) has updated their checklist entries to include the changes. However, as a TPA, we are waiting for final guidance before we contact Clients regarding their preferences.