EPCRS Death RMD & Proposed Regs

[DTH]

A participant died in 1999, his son is his sole designated beneficiary. I am doing an EPCRS calculation back to 2000. When I do the 2001 RMD what life expectancy factor do I use since this was during the re-proposed RMD regulation transition rule period. The beneficairy was born in 1960.

For 2001:

Do I use the new Single Life Table looking at his age in 2000 minus 1 (i.e., 43.6 - 1 = 42.6 for 2001 LE)

Do I use the new Single Life Table looking at his age in 2001? (i.e., 42.7)

This has downstream impacts as I reduce 1 for subsequent life expectancy factors.

Thank You!!

[ETA Consulting LLC]

I'd keep the method consistent. The single life factor in the year following the year of death (2000); reduced by one each subsequent year. So, I'd use the "new 2000" factor and subtract by one.

Good Luck!