We have not experienced major pension reform recently, but it is important for nonprofit and governmental plan sponsors to not be lulled into a false sense of security.
Sponsors of 403(b) and 457(b) plans should be thinking about several things in light of recent regulatory and litigation developments, and perhaps take action on them now. We would like to highlight the following areas:
New hardship rules for 403(b) plans
Regulations proposed in late 2018 permit (but do not require) plan sponsors to eliminate the 6-month suspension period on employee contributions (401(k), 403(b), after-tax, and Roth) beginning for hardships distributions in plan years beginning after 2018.
However, for hardship distribution made on or after January 1, 2020, no suspension will be permitted for any plan.
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