RMD plan terminated

[52626]

Employer terminated 401(k) Plan and he rolled his account balance to his DB Plan in March 2014. At the time of the roller the participant had not attained the age of 70 1/2 ( turned 70 1/2 in Sept 2014).

Participant's first RMD from the DB plan is 4/1/2015, however, he has elected to take first payment in 2014 to avoid two payments in 2015.

since the 401(k) was rolled before he attained 70 1/2 I am trying to determine when does the rollover get included in calculating the RMD. My thought is the rollover get included when calculating the 2015 RDM.

Thoughts

[BG5150]

You are subject to the RMD rules for the calendar year in which you turn 70 1/2. If a distribution is done in that year, but before the participant turns 70 1/2, then you still have to take the RMD first.

I think you have an ineligible rollover to the the DB plan and the RMD money has to be returned to the plan to be paid out as an RMD.

[ESOP Guy]

I agree with BG5150 the 401(k) plan should have paid an RMD for 2014 before it paid a distribution to this person.