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If you were born born between July 1, 1948 and June 30, 1949, then you turned 70.5 in 2019 and your first distribution calendar year is 2019. RBD is 4/1/2020. If you were born between July 1, 1949, and December 31, 1949 then you will turn 72 in 2021 and your first distribution calendar year is 2021. RBD is 4/1/2022. The only people whose RBD will be 4/1/2021 are non-5% owners who were born 1948 or earlier (age 72 during 2020) and terminate employment during 2020.

It's my understanding that the Act is effective for distributions made after 12/31/19, and are for individuals who attain age 70 1/2 after 12/31/19: This requires an amendment to the document provisions and is optional; plan sponsors may choose to retain an earlier age.

We'll have the chauffer deliver a copy to you.

SEC. 114. INCREASE IN AGE FOR REQUIRED BEGINNING DATE FOR MANDATORY DISTRIBUTIONS. (a) IN GENERAL.—Section 401(a)(9)(C)(i)(I) of the Internal Revenue Code of 1986 is amended by striking ‘‘age 70-1/2’ and inserting ‘‘age 72’’. (b) SPOUSE BENEFICIARIES; SPECIAL RULE FOR OWNERS.—Subparagraphs (B)(iv)(I) and (C)(ii)(I) of section 401(a)(9) of such Code are each amended by striking ‘‘age 70-1/2’’ and inserting ‘‘age 72’’. (c) CONFORMING AMENDMENTS.—The last sentence of section 408(b) of such Code is amended by striking ‘‘age 70-1/2" and inserting ‘‘age 72’’. (d) EFFECTIVE DATE.—The amendments made by this section shall apply to distributions required to be made after December 31, 2019, with respect to individuals who attain age 70-1/2 after such date. https://www.congress.gov/116/bills/hr1865/BILLS-116hr1865enr.pdf Page 623

Having formerly written and maintained applications with an Access DB backend, I will say that you probably outgrew it the minute more than one person needed to use it at the same time. That said, there are some interesting document management solutions out there, but as for us, we just use a plain-old folder hierarchy, which used to live on our own file server, and is now on one of the big cloud storage providers. Anything that comes in a non-electronic form gets scanned and saved to the appropriate client folder.

khn, if it is paid by the plan, the plan is the client and the amount of the expense would come within the ambit of the plan administrator's fiduciary responsibility. If it is paid by the plan sponsor, not the plan, then depending on the subject of the advice or other legal service, it may still be for the plan, but in such a case only the quality of the service, not its cost, would be a fiduciary responsibility. Because of the lack of transparency regarding legal fees and, arguably, comparability, it will be very difficult to benchmark. I think most sponsors pay plan-related legal fees as an employer expense partly for this reason.