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Posted

I have a participant who turned 70.5 in 2013, but at that time he wasn't eligible to receive his pension.  The 2016 Plan Year was his fifth, making him eligible to start receiving a pension (though he is still actively working and has already accrued another year of service in '17)..

So what would the required start date be for his RMD? He wasn't eligible on the 4/1 following the year in which he turned 70.5. 

Thanks in advance!

Posted

Dumb but pertinent question - is this person a 5% owner?

If not, then the  required beginning date will not be reached until the April 1 after the year of separation from service (and I presume that "retired" is treated, for this purpose, universally as being the same thing as separating from service within the plan sponsor's controlled group).

If the person is a 5% owner, the first 2 or 3 required distribution dates have gone by with nothing payable since the person had not completed the requirements for vesting (assuming that is the significance of 2016 being his 5th year).  I don't think that the April 1 date would have any significance (the first RMD date, with nothing payable, having been April 1, 2014), with all due dates being December 31st of the relevant year, but don't take my word for it.

Always check with your actuary first!

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