Plan sponsors have been anxiously awaiting additional guidance affecting hardship withdrawals since the changes brought by the Bipartisan Budget Act of 2018, and nearly nine months to the day the IRS finally delivered with the issuance of proposed rulemaking. With the exception of the elimination of the six-month suspension of elective deferrals, the provisions of the proposed regulations generally apply to hardship distributions made in plan years beginning after December 31, 2018.
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