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Posted

1st question: When notifying a participant of his need to take a Required Minimum (RMD), are you required to send them a tax notice? For example, if you notify the participant in October that an RMD is needed by 12/31 and you give him an election form, are you required to also provide a tax notice? Since the RMD is inelgible for rollover, I wasn't sure if the tax notice requirement applied.

2nd question: Can a participant who is married and elected to use a single life factor, chose to use a joint life expectancy factor after a few annual payments have been made? If so, can the participant just elect a change, or must he have had a maritial status change?

Thanks

Posted

On your 2nd Q:

What election are you talking about? There is only one minimum, based on a comparison of all alternative rules. If the person is taking out amounts that are greater than the minimum (based on using an alternative that isn't the actual minimum), that doesn't mean they have "elected" to ignore the minimum. If another calculation methodology produces a lower minimum, they ought to be able to use it. I don't see that there is any election involved.

Posted

I guess by election, I was referring to the form they return to the TPA firm indicating the factor they will be using to determine the RMD amount.

Perhaps I didn't do a very good job asking the question either. Let me try again with another scenario.

Say you have a married participant who has designated his spouse as his beneficiary and is using the joint life expectancy factor. He has been receiving payments for 3 years and now would like to change his beneficiary to someone other than his spouse (with her permission) and would like to start using the single life factor to calculate his RMD amount. Is this okay? Is there any reason it isn't?

Posted

Does the plan permit a change in the form of distribution after commencment date? Not common.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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