RMD at time of Plan Termination

[WesleyT]

Does a plan termination trigger Required Minimum Distributions for non-owners?

Example:

Participant (72 years old, non-owner) is still employed. Plan terminates as of 12/31/2008, assets to be paid out late in 2009. Does this require the participant to take an RMD as of 4/1/2009? Or does the participant's actual distribution trigger the RMD?

[ERISAnut]

No, it doesn't. However, a full distribution is likely within 12 months after plan termination. This will likely be rolled into an IRA (where the distributions will be required to begin). As long as the distribution and rollover takes place after 12/31/2008, there will be no RMD from the IRA until 2010 (as the beginning balance for 2009 would have been $0).