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401(k) Plan Sponsors: Time to Revisit Your Hardship Withdrawal Provisions
Verrill Dana LLP [Guidance Overview] July 9, 2018 "Will a plan be treated as satisfying the regulatory safe harbor if it retains the 6-month suspension period for purposes of making elective deferrals and employee contributions? What happens to participants whose 6-month suspension period has not yet expired when the change to eliminate the suspension period becomes effective? Will a plan be treated as satisfying the regulatory safe harbor if it retains the requirement that a participant must first obtain any available plan loan before taking a hardship withdrawal?" |
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