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SPARK and American Benefits Council Recommendations to IRS on Hardship Distributions and Loans (PDF)
The SPARK Institute and American Benefits Council 
[Opinion] May 4, 2015
"We are very concerned that the Service appears to have released a new position in a 'newsletter' -- which cannot be relied upon by plans and their service providers as authoritative, but results in confusion about compliance with the hardship distribution rules. This is not the proper process to resolve a longstanding and significant plan qualification issue.... The same newsletter has raised a series of concerns and questions regarding loans, particularly principal residence loans."
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