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I am trying to determine when the first RMD is due for this participant in a Cash Balance Plan.

Details:

- Participant is 100% owner of the plan sponsor.
- Participant turns 70 1/2 in 2018.
- Plan's original effective date = 1/1/2018.
- End of year (12/31) valuation date.
- Plan excludes service prior to the effective date of the Plan for vesting purposes, and the vesting schedule is a 3 year cliff.

Would the first RMD be due 4/1/2021?

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I forgot to mention an important detail too (since added to original post) that the participant is the 100% owner.

NRA = later of 65 or 3rd anniversary of Plan participation date. So, his NRA would be 1/1/2021.

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First distribution calendar year is 2018. RBD is 4/1/2019. However participant is not vested at that point so no benefit is payable.

As of 12/31/2019, participant has 2 years vesting service and is still not vested. Still no benefit payable.

Upon completing a third year of vesting service in 2020, the benefit becomes payable. Exactly when could depend on how the plan defines a year of vesting service, however if benefits commence by 12/31/2020 you should be ok.

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