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ARTICLE · 08 APRIL 2015

Plan Sponsors Must Maintain Documentations For Hardship Distributions And Loans

In a recent "Employee Plan News" issued by the Internal Revenue Service ("IRS"), the IRS emphasized that plan sponsors are ultimately responsible for proper administration of their retirement plan...

United StatesEmployment and HR

In a recent “Employee Plan News” issued by the Internal Revenue Service (“IRS”), the IRS emphasized that plan sponsors are ultimately responsible for proper administration of their retirement plan and thus, must maintain documentation of hardship distributions and plan loans even if a third party administrator (“TPA”) handles these transactions.  The IRS stated that a failure to provide these records during an IRS examination is a qualification failure that should be corrected using the Employee Plans Correction Resolution System (“EPCRS”).

Documentations for Hardship Distributions

Plan sponsors can retain these documents either in paper or electronic format.  The following is a list of the documentation that must be maintained for each approved hardship distribution: 

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