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SECURE’s revision of Internal Revenue Code § 401(a)(9) distinguishes between an eligible designated beneficiary (a beneficiary who is: the decedent’s spouse, disabled, a chronically ill individual, no more than ten years younger than the decedent, or the participant’s child “who has not reached majority”) and a designated beneficiary who is not so classified. Imagine a § 401(a) plan provides that every kind of distribution is paid only as a single sum. And that a retirement distribution or death distribution is paid only as a single sum of the entire account. Assume the plan’s governing document does not otherwise require a beneficiary to take a distribution any sooner than is necessary to meet § 401(a)(9) to tax-qualify. With those provisions, is there any plan-administration purpose for which the plan’s administrator needs to know whether a beneficiary is an eligible designated beneficiary? Or must either kind of designated beneficiary get the death distribution by the end of the tenth calendar year that follows the year of the participant’s death?

A vested terminated participant has been taking RMDs the last few years from the qualified DC plan using the ULT table (the one that assumes a 10-year younger spouse). Suppose this year we are told that, all along, their spouse (and designated beneficiary) is actually 20 years younger than they are. Does that mean the joint table (with its larger divisor factors) is required to be used for determining the RMD? If so, was 20% mandatory withholding missed on the non-RMD portion of the amount distributed for the prior years because those amounts could have been rolled over?

A plan will file a voluntary correction for late RMDs. Some of the late RMDs are due to lost participants. Is the inability to make a payment due to inability to find a participant (despite multiple and varied efforts) a plan error?