RMD Account Balance

[Guest nlmc18]

When determining the participant's account balance as of the prior plan year end, do I include receivables?

[Harwood]

"As of" reporting for the RMD balance permissibly can be ignored

§ 1.401(a)(9)–5 Required minimum distributions from defined contribution plans.

Q–3. What is the amount of the account of an employee used for determining the employee’s required minimum distribution in the case of an individual account?

A–3. (a) In the case of an individual account, the benefit used in determining the required minimum distribution for a distribution calendar year is the account balance as of the last valuation date in the calendar year immediately preceding that distribution calendar year (valuation calendar year) adjusted in accordance with paragraphs (b) and © of this A–3.

(b) The account balance is increased by the amount of any contributions or forfeitures allocated to the account balance as of dates in the valuation calendar year after the valuation date. For this purpose, contributions that are allocated to the account balance as of dates in the valuation calendar year after the valuation date, but that are not actually made during the valuation calendar year, are permitted to be excluded.

© The account balance is decreased by distributions made in the valuation calendar year after the valuation date

[Guest Ashley]

The model amendment does not support disregarding receivables (although the final regulations do).

[Harwood]

Ashley - good catch!