2009 RMD Waiver

[QLAC Annuity]

In addition to waiving 2009 participant RMDs, 401(a)(9)(H) also changed the RMD rules for beneficiaries under the life-time annuity rule and 5-year rule. Can anyone cofirm the following points?

With respect to participants who died in 2008, beneficiaries have one additional year, until Decemebr 31, 2010, to elect the life-time annuity rule.

For participants who died in 2004 through 2008, the 5-year rule is extended by one year (e.g., for a participant who died in 2004, beneficiaries must complete distributions by Decemebr 31, 2010).

The 2009 RMD waiver has no effect with respect to participants who died in 2009.

[Guest Sieve]

Yes to all. See Section V of Rev. Proc. 2009-82, here: http://www.irs.gov/pub/irs-drop/n-09-82.pdf