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Plan is terminating, not the participant: RMD needed?


AlbanyConsultant
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I can't believe I've never seen this before, but...

 

I've got a 71+ year old non-owner participant not taking RMDs because she is still employed.  The plan is terminating in 2018 , but not due to the business closing, so the employee is still going to be employed.  Does she have to take a 2018 RMD before she can roll over the remainder of her distribution?  Thanks.

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I agree with Mike, but the plan termination will create a subsequent RMD for this person once the distribution is rolled over, assuming it goes to an IRA and not another plan of the employer. However, that becomes her responsibility and not the plan's (or yours).

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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I am perfectly OK with this being SEP (Somebody Else's Problem).

 

And, to Mike's point above, the language does seem to support that the RMD does not need to be paid out because she is not retiring.  I emailed a question to the doc provider this morning, but haven't heard back yet (it's Datair's new pre-approved 403(b) plan doc).

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