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Posted

A 401k participant (not an owner) with a DOB of July 1939 terminated on 12-31-2012, making his RBD 4-1-2013. The investment company's computer system calculated his RMD based on his account balance on 12-31-12 divided by a factor of 23.8 for age 74.

In my opinion, since his first distribution year is 2012, the calculation should be based on his balance as of 12-31-2011 and a factor of 24.7 / age 73.

Who is correct?

Posted

Susan, I agree with you on this RMD.

I have a related question, though, for anyone out there, dealing with termination on December 31. I have a non-owner participant who is age 71. The Plan was terminated on December 31, 2012. The company he worked for was then acquired in an asset sale effective 1/1/2013. The new company is not adopting the Plan. The last payroll received from the Plan Sponsor was on 12/31/2012. Is this participant considered terminated, and if so, as of December 31 or January 1?

Posted

Susan- Both correct (but you're more correct) because he has to take 2 distributions this year, one by 4/1 for 2012 and one by 12/31 for 2013.

TPATC - Terminated on 12/31 (and thus needs to take an MRD for 2012 by 4/1).

Kurt Vonnegut: 'To be is to do'-Socrates 'To do is to be'-Jean-Paul Sartre 'Do be do be do'-Frank Sinatra

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