"[F]or safe harbor plans, if the new hardship rules were not described in the 2020 safe harbor notice, employees must be provided an updated notice to reflect the new hardship withdrawal provisions and must be given the opportunity to change their election.... [It] is likely not practicable to provide the notice in advance of the January 1, 2020 effective date of the plan amendment ... [T]he notice should be provided as soon as practicable, but no later than 30 days after the amendment is adopted."  MORE >>