Missed RMDs

[Just Me]

Defined benefit plan didn't begin required minimum distributions to former employee at age 70-1/2. The company intends to make a "catch up" contribution for the missed monthly payments, and beging monthly payments going forward. Participant is married. The Plan does not have retroactive annuity starting date provisions. IRS agent unofficially says we can make the "catch up" payment without needing RASD provisions. The question is whether the participant can elect the form of benefit payable, or must the plan just pay him the 50% J&S because his spouse did not retroactively waive that form of benefit? (And in the absence of his timely election, he just gets the normal form of benefit of the 50% J&S when RMDs start).

[masteff]

Can't speak to it in terms of an MRD but at my former job, when someone exceeded normal retirement date w/out returning the proper forms, we'd issue any past payment in the plan's default form of payment and allow the participant to make a proper election (ie w/ spousal consent) for future payments. We also applied appropriate compound interest to the past payments.