Do the "adverse financial consequences" apply only to the participant or does it include the participants spouse or children - similar to the "diagnosed" criteria?
Initially, “adverse financial consequences” applied on a participant level. IRS guidance provided in Notice 2020-50 expanded this list to include a spouse or a member of household.
“Member of the household” is someone who shares the qualified individual’s principal residence, which encompasses a broad group of individuals such as a relative, roommate, significant other, or anyone else with whom the individual is sharing a home.
Cetera Retirement Plan Specialists is a third-party administrator and may not offer tax, legal or investment advice. Plan sponsors should consult their own tax, legal or investment professionals.