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Time is Right to Contact Recordkeepers About Hardship Substantiation
Proskauer's ERISA Practice Center 
[Guidance Overview] May 24, 2017 "The IRS's openness to substantiation in a summary form will be welcome news to many administrators and plan sponsors. But accepting summary substantiation will require careful review by the recordkeeper and, even with that review, administrators and sponsors will have to rely on participants to maintain records.... Plan sponsors should consider whether the efficiency from reduced documentation is worth the potential for headaches in an IRS audit." |
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