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David Peckham

Changing the annual annuity date for a DB participant taking RMDs

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Participant A is age 77, so he has been taking annual RMDs for 7 years. In his first RMD year, he took out his RMD in December. Every year since then, we have advised taking his RMD in December and not any earlier to satisfy the "generally consistent" annual annuity distribution that he would be receiving from an insurance company if his annual annuity came from such as source.

Now, he is really pressing us to allow him to take his RMD earlier in the year. Can we make some sort of one-time adjustment to allow this? He would like to switch to taking his annual RMD on March 15th every year.

 

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How are his RMD's determined, i.e. what is the payment interval?   How much was taken in the first year and how was that determined?

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Sorry, Andy, for not responding earlier. I have attached a pdf file and Excel file showing our calculations.

Comments?

(EDIT 06/07/19.  Personalized attachments are removed.)

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Please reconsider your attachments.  Too much personal detail.  Make it anonymous.

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Off the shelf, I believe the time of the distribution can be changed. There should be a good administrative reason for the change, as documented by the Plan Administrator. The PA should explain to the participant that the timing cannot be changed again, as the IRS may claim this doesn't satisfy 401(a)(9).

It's my money and I need it now is not enough of a reason.

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