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New Hardship Distribution Guidance Brings Several Surprises
Proskauer's ERISA Practice Center [Guidance Overview] Nov. 13, 2018
"Depending on when a plan sponsor eliminates the 401(k) suspension period, there could be related consequences for administration of the nonqualified deferred compensation plan.... [E]arnings on pre-tax deferrals made to a 403(b) plan continue to be ineligible for hardship distributions. However, QNECs and QMACs would be eligible for hardship distributions in a section 403(b) plan that is not in a custodial account."
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