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yttap

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  1. His official termination date was 5 days after he died. This is per the plan contact. It is a DC plan.
  2. *Both PARTICIPANT and Spouse Have Died before RBD
  3. Hi, A non-owner participant, DOB 01/22/36, terminated on May 10, 2022. His RBD was 4/1/23, I believe. His RMD forms were forwarded in late 2023 to the plan contact when I learned of his termination. The contact never returned the forms because she never heard from the participant. It turns out he died on May 5, 2022. Primary Beneficiary was his wife, DOB 2/6/40. Turns out the wife died March 18, 2023. Her Beneficiaries are their two adult sons. Questions: 1. I am right to think that since participant died before his RBD, no RMD’s are required for 10 years? (Per a certain webcast) 2. Since the wife died before his RBD, are the distributions still delayed for 10 years? Is the wife now considered the participant when using the tables? Which table? This has stumped me and my colleagues. One colleague suggested that this is pre-Secure, so the old rules apply, which really confused me. Help!
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