RMD question - Non-owner, still working

[Spencer]

I have a participant who is 70.5, and a non-owner. He has terminated employment with his long-term employer and sponsor of his 401k account. But he has a part-time job now. Does the "still working" exception apply? Can he defer RMDs until he stops working entirely? or since he has terminated employment with the sponsor of the 401k, does he have to start?

Thanks!

[Lou S.]

You have to be working for the sponsor of the 401(k) plan for the expection to apply.