The reason I never hired an employee is because I was an employee once too. I had co-workers, many of who I couldn’t trust (I did work for a couple of law firms).

As far as plan sponsors relying on certifications for hardship distributions, that’s not something I’d go for as a plan sponsor. I’d still want to vet any hardship distributions. Otherwise, I fear that certifying is nothing more than a pinky promise that you abide by the rules, which is a hard pass for me since every issue for a participant will become a hardship.

The rules are the rules to me, I like enforcing them. If my liability is dependent on the plan, I want to make sure any hardship distribution request is on the up and up, especially the slim chance that the Internal Revenue Service will audit the plan and hardship distributions.