Late RMD

[cpc0506]

First RMD was due for a participant by April 1, 2017.  The RMD was not processed timely.  Participant did not receive the RMD until just last week.

Would you report this 'failure to provide a benefit when due on the 2016 Form 5500-SF line 10f or the 2017 Form 5500-SF line 10f?

[ETA Consulting LLC]

No. You never restricted the participant from requesting a receiving a distribution.  Had the participant actually requested a distribution back in 2016, they would've been paid.  You merely failed to provided the RMD by the deadline, but that appears to be more of a IRS compliance issue.  Failing to provide a benefit when due appears to be more of an employee rights issue (under the DOL's purview).

Good Luck!

[Belgarath]

The instructions on the SF appear to be different than for the 5500 See the following from the instructions for the Schedule I:

Line 4l.  You must check “Yes” if any benefits due under the
plan were not timely paid or not paid in full. This would include required minimum distributions to
5% owners who have attained 70½ whether or not retired and/or non-5% owners who have attained 70½ and have retired or separated from service, see section 401(a)(9) of the Code. Include in this amount the total of any outstanding amounts that were not paid                       
                 e continued to remain
unpaid.

Pardon the incomplete copy/past above - it didn't completely work, but there's enough to get the gist.
 

[cpc0506]

5 minutes ago, Belgarath said:

The instructions on the SF appear to be different than for the 5500 See the following from the instructions for the Schedule I:

Line 4l.  You must check “Yes” if any benefits due under the
plan were not timely paid or not paid in full. This would include required minimum distributions to
5% owners who have attained 70½ whether or not retired and/or non-5% owners who have attained 70½ and have retired or separated from service, see section 401(a)(9) of the Code. Include in this amount the total of any outstanding amounts that were not paid                       
                 e continued to remain
unpaid.

Pardon the incomplete copy/past above - it didn't completely work, but there's enough to get the gist.
 

I agree that the late RMD should be reported.  That is how we have always handled this.  My question still remains: would you report on the 2016 Form 5500 or 2017 Form 5500?  The first RMD due by 4/1/17 was the 2016 RMD.

[RatherBeGolfing]

You report it on the 2017 Form 5500 because it was due in 2017 even though the first distribution year was 2016.  As of 12/31/2016, you had not yet failed to timely pay the benefit.

[Belgarath]

But it wasn't "due" until 4/1/2017. So you report it on the 2017 form, if you are going to report it at all.