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Posted

Our money purchase pension plan currently provides for the first of each month as the distribution date. I take this to mean that if there are any participants that become entitled to benefits during the month, distribution of those benefits will commence on the first of the following month.

This is very cumbersome to administer. What does the law say as far as commencement of distribution of benefits? Could we limit this to once or twice a year? Can someone point me to the relevant legal guidance on this?

Thanks.

Posted

You will want to look at 1.411(d)-3 and 1.411(d)-4.

The de minimis timing change rule in 1.411(d)-4, Q&A 2 (b)(2)(ix) will help if you can live with changing the timing by no more than two months. It's six months for in-service distributions.

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