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Is this for a DB or DC plan? The rules differ. I will state my answers for a DB plan ...... 1. For an annual payment by 4/1/2023, RMD payment should be the annual RMD, $24,000. April 1 is a BEGINNING date, for monthly payments, but for an Annual RMD, you should pay the entire Accrued Benefit x12 as of 12/31/2022. 2. At least $24,000, plus an interest adjustment (actuarial increase) for delayed payment that was due 4/1/2023. There is also potential 50% Excise Tax for missing 4/1/2023 deadline. What/when is the NEXT RMD payment going to be? 3. $36,000 should be received in 2024. I think this should be paid around 4/1/2024 (or 1st anniversary of 2023 payment, if earlier than 4/1/2023). .... Jeff

If a blank line calls for filling-in a date on which something became, becomes, or will become applicable and the writing does not otherwise state that date, one might worry about an incomplete expression. But if a fill-in would be merely a recital of when something was signed (I’d ignore the nonsense about “executed”) and there is useful evidence of when it was signed, what incompleteness would a maker worry about?

If all your rate groups (not including deferrals) pass at 70%, then you don't need to pass the average benefits percentage test (which does include deferrals).

I wouldn't be too hard on yourself. I just read the ASPPA update that a technical error has now eliminated all catchups effective for January 2024.

I've actually found that by being "consultative" (an overused word, to be sure) and explaining things to them to be a good client relations technique.... Something about striving to be a "trusted advisor" by giving them what they *need* instead of what they *want*.

Too much detail, not enough time, and too few functioning brain cells remaining. I'm getting too old for this stuff!

It’s Congress that set this penalty. The Labor department merely announces the non-discretionary inflation adjustment.

Yeah, me too. I missed this little detail entirely. So Gilmore - looks like you had it right! I did send this question to ERISApedia for their Q&A session (late February) just to see if they concur.

Re-upping this. In ASPPA webcast yesterday, the presenters had a discussion after the slide on this subject was shown. What I understood (or misunderstood) them to say was that pre-2023 eligibility service was not ignored for 401(k) - only for 403(b), so that for 401(k) purposes, someone who had 500 hours in, say, 2022 and 2023, but not in 2024, would enter on 1/1/2025. Did anyone else watch this, and if so, did you hear the same thing?

If the plan says monthly benefit and does not provide an annual annuity option (check the specific RMD provisions too which may give additional options), you're stuck with what the plan says and must pay monthly benefits. (So the answer is that neither 18K nor 24K is permitted. Only if the Plan permits an annual annuity can you pay out an annual form of pmt. And even then the amount must be actuarially determined, and it will be somewhat LESS THAN 24K but not exactly 24K.) There are a lot of unknowns here. Is the $2000 monthly amount actuarially adjusted from Normal Retirement Date to the 4/1/23 starting date per the terms of the Plan? Same for the accrual for 2023--it must be adjusted to whatever starting date for the increase. Probably the easiest thing is to start the increase on 1/1/24 though you might be able to start the increase 4/1/24 (appropriately actuarially adjusted)--but check the terms of the plan as to what is permitted or required. DB RMDs are messy. That's why I always design my plans with annual annuities permitted for RMDs, and frequently use an in-service distribution as a means to both simplify the RMD process and to simultaneously de-risk the plan at the same time. And maybe capture maximum 415 limit benefit too. And don't miss the 4/1 start date! They are focused on it now so no excuse. Excise tax will apply. (Does Secure 2.0 reduce the excise tax this year or at a later date??)

To the extent there is a tax-qualification failure to correct, consider that SECURE 2022 § 305 undoes the Internal Revenue Service’s time limit on which failures are eligible (if otherwise eligible) for self-correction.

Invoice him $300 for researching what to do with an unallocated forfeiture account.

I'm assuming this also means that an ee with 500 hours in 2021 and 2022, but not 2023 or 2024 would be eligible as a LTPT on 1/1/2025?