RMD calculation

[pmacduff]

I know this is an easy question but I'm frazzled today -

Participant waived 1st RMD due 04/30/2010. To compute the RMD due by 12/31/2010...I still use 26.5 from the uniform table and the last val balance so in essense it's the same $$?

[Mike Preston]

DId you mean 4/1/2010? I don't know how a participant can waive an RMD due by 4/1. I think you have an RMD violation. Are you confusing the fact that a participant with a 4/1/2010 RBD actually has an RMD for 2009 that can be avoided by deciding to take it in the next calendar year (by 4/1/2010) with something else?

[Bird]

Mike, RMDs for 2009 were waived, so if we are talking about a first RMD due 4/1/2010, that's for 2009 and was waived.

pmacduff, if the divisor was 26.5 for 2009 (age 71) then it is now 25.6 (age 72) and also you use the 12/31/09 balance, not 12/31/08, so both numbers are different.

[pmacduff]

I did mean 04/01/2010 Mike and it was the 1st RMD due.

Thanks Bird, this is actually an off calendar PYE of 03/31, only annual vals. My software was calculating a number that didn't match what I computed, so I wanted to be sure I was using the right figures and divisor.

[Mike Preston]

While there are technical requirements that a plan has to meet in order to skip the 2009 RMD (amend the plan at some point to conform the plan language with the plan's operation), most people just assume that 2009 RMD's for DC plans (and 414(k) accounts within DB plans) were, as the OP stated, "waived" by the participant.

I prefer to think of the RMD requirement as being just that unless or until somebody tells me that the plan has made arrangements to satisfy the RMD waiver made available.

In any event, I certainly agree with your numbers, Bird.