RMD - DB to DC and Off Calendar

[Guest Twinky]

I have a situation where...

First, the plan has an off calendar plan year (Oct 31).

Second, the company terminated their DB plan in 2006

Third, they started a 401k plan in 2006 (eff 11/1/06)

Fourth, the participants rolled their money into the 401k plan (during Oct 2006 - before the PYE of prior year - issues I'm dealing with, since the effective date is 11/1)

Fifth, the accounts are individual (pooled) accounts at the investment company

In determining the balance to use to calculate the RMD, I would use the balance as of 12/31/06...correct? (not Oct 2006)

Thank you so much!