RMD calendar year date? Is it date processed or check date to comply?

[Guest Matt Young]

Reg 54.4974-2 Q-1A states that the RMD for a calendar year to be distributed during the calendar year. If the RMD's were processed from the Recordkeeping system in 98 but the checks are dated in 99, does this comply with 54.4974-2? Where else may this be clearly defined?

[LCARUSI]

Prop Reg 1.401(a)(9)-1 talks about a distrbution being made by a specific date. It sems to me the intent is clear - that the payment must be issued by this date. Therefore, to commence processing as of that date or to value a payment as of that date would not satisfy the requirement. I think the most wiggle room you have is for the check to be dated on or before the required date, even if the participant does not receive it for several days thereafter.

That having been said, rules relating to RMDs have been changed and the payments can be delayed until retirement for employees who are not 5% owners.