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Posted

Has anyone dealt with the situation where a DB plan former participant is/has turned age 70-1/2 and needs to begin to receive an RMD, is not responsive to attempts to contact him by the Plan Administrator, and his/her marriage status is unknown? They are trying to avoid having to modify the annuity form after it has begun (i.e., initially provide a single life annuity, but find out a participant is married and then have to switch to a J&S; or vice-versa).

Should the Plan assume the participant is unmarried (even if records may say otherwise), provide a single-life annuity, then switch to a J&S if they find out the participant is married (kind of like deeming the modification to be on account of the participant's marriage under the 401(a)(9) regs).

Do the opposite?

Also thinking about providing a long-term period-certain, which could then be changed to an annuity under the regs, but what if the plan doesnt allow this?

Thanks.

Posted
... and his/her marriage status is unknown...

Can't you just ask?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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