Post-Acquisition Terminated Plan - RMDs required?

[Jennifer J]

We sold our ESOP company in early 2018. The Plan has been terminated with the IRS. We have an independent Trustee who chose to distribute 80% of the sales proceeds to all participants in 2018, but withheld 20% for unanticipated expenses (like a mini escrow). The question is, does the Trust have to process RMDs for 2019 on a terminated plan? Any experience or advice on this topic would be greatly appreciated.

[Lou S.]

As long as the Plan's Trust is in existence you must comply with the RMD rules under 401(a)(9).

[Jennifer J]

Thank you. That is what we did.