In our Client Alert earlier this month click here to access , we alerted you to certain changes made by two Acts of Congress—the Tax Cuts & Jobs Act (“TCJA”) of 2017 and the Bipartisan Budget Act (“BBA”) of 2018—to hardship distribution rules affecting employer defined contribution retirement plans (primarily 401(k) and 403(b) plans). As we noted there, although the effective dates for some of those changes were fast approaching (and some had already passed), a number of questions still remained unanswered because the Internal Revenue Service (“IRS”) had not then yet issued the necessary guidance. Finally, on November 9, 2018, the U.S. Department of Treasury and IRS did release such guidance, in the form of proposed regulations (“Proposed Regulations,” which were published at 83 Fed. Reg. 56763 (11/14/2018)). We believe that affected employers and other interested parties will find most of this guidance welcome and still timely enough for appropriate plan design changes to be made for 2019 and participants to be timely notified. The highlights of the Proposed Regulations are discussed below.