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Hojo, Draper is talking about the floor stated in 404 that points back to 430. That is, the maximum is not less than the minimum using at risk rules. I don't have time to cross reference but I would think MAP-21 affects all things 430. So, if there is an at-risk bump up it will be muted due to MAP-21.

To be precise, the law does not prevent discrimination, but places limits on it. Again, this is what pension law thinks of the fairness concept.

Lou: I was hoping someone else would answer and I am not going to be a deep well of knowledge here. Of all your questions I have only seen one of them before and this is how we decided it. We had a person in this situation and oddly also had 4 children. We split the RMD 4 ways. Your other situations never crossed our mind- for example give one of the kids the whole RMD or if their distribution was large enough and wasn't rolled over did that cover it. I guess what I am saying is in our minds on the day of the participents death we started treated it as if we really had 4 seperate accounts that had to have the death RMD rules applied to them all. The following year the plan allowed for 100% payment to the children so it stoppped being our problem. I can't quote you anything it seems like you haven't read like the 401(a)(9) regulations.