2009 MRD suspension

[Guest Sieve]

There is no exception from the 2009 MRD suspension in a non-spouse rollover context, correct?

[jevd]

There is no exception from the 2009 MRD suspension in a non-spouse rollover context, correct?

Yes. See Rev Notice 2009-9 HERE

[J Simmons]

Just to be clear, there is no minimum distributions required of a non-spousal rollover for 2009? Is that what the question is, and what jevd confirmed?

[jevd]

Just to be clear, there is no minimum distributions required of a non-spousal rollover for 2009? Is that what the question is, and what jevd confirmed?

That's my understanding. Any required distribution for 2009 including those required of beneficiaries are suspended. That includes spouse and non-spouse beneficiaies. I believe that's what the OP meant.

Sieve,

Are our assumptions correct?

[Guest Sieve]

My question was whether the 2009 MRD suspension applies to ALL MRDs, specifically including a beneficiary who has rolled over from a qualified plan to an IRA in a non-spouse rollover. I understand your answer to be that the suspension applies to all MRDs, whether to a participant or a beneficiary, and whether or not a non-spouse beneficiary has rolled over into an IRA.

[jevd]

My question was whether the 2009 MRD suspension applies to ALL MRDs, specifically including a beneficiary who has rolled over from a qualified plan to an IRA in a non-spouse rollover. I understand your answer to be that the suspension applies to all MRDs, whether to a participant or a beneficiary, and whether or not a non-spouse beneficiary has rolled over into an IRA.

Correct.

[John Feldt ERPA CPC QPA]

But MRDs for DB plans were not suspended.

[jevd]

But MRDs for DB plans were not suspended.

Correct