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New loan policy needed?????

The rules for refinanced loans are in 1.72(p)-1, Q&A 20. Depending on the exact situation, it can get interesting. I find it helps to have the reg in front of me when looking at it.

@Appleby The ERISA Outline Book by Sal Tripodi

Here is what the EOB says RMD has to be taken out if it is a required distribution year. Since she is still employed, an RMD is not required for 2018. If she terminates during 2018 after the distribution has been made, 2018 will become a required distribution year, with no assets left to make the RMD. If that happens, the distributing plan is still treated as having satisfied its minimum distribution requirements, but the the recipient plan will have received an invalid rollover amount.

The employees are the Doc's employees, not the employees of the PEO. Think of a PEO as a fancy payroll service. Of course they have to counted in the doc's plans!

Assuming she puts the money into an IRA that had no other assets in it until this rollover it is 2019. Any 2018 RMD from the IRA is based on the balance at 12/31/2017 which would be zero-so the RMD is zero. The other catch is she can not terminate employment during 2018. The moment she does that there would need to be an RMD from the 401(k) plan even if there is no cash in it at the time.

Awwww. You warm this old gal's heart.

Patricia, we posted virtually the same answer at same time and yours was not visible to me until I hit Submit Reply, so I gave you a heart.

BT, was the PSP sponsored by the same business, i.e., your business, or was it sponsored by someone else?