Terminated participant 2018 RMD required or not

[DDB BN]

The 2018 census indicated that an employee was on leave as of 01/01/2018 (given the nature of the client's business, this is common).  The 2019 census indicates that the employee is retired as of 01/01/2018.  Participant's DOB is 10/20/1948.  Should this participant be required to take an RMD now for 2018 which would have been due by 04/01/19 prior to distribution of her remaining benefit in the plan which will be rolled over to an IRA?  

[Mike Preston]

Aren't you off by a year?

[Lou S.]

I think by dumb luck you may be OK on this one assuming it's not a DB plan.Based on the DOB they don't turn 70 1/2 until 2019  and the RBD for the 2019 RMD was 4/1/2020. The Cares Act suspends RMDs for 2020 and provides also provides relief for 2019 RMDs with a RBD of 4/1/2020 if they weren't already made.

 

[DDB BN]

It is a safe harbor 401k.  And yes, I am off by a year.  Calculated age 70 1/2 based on DOB of 01/20/1948 in error instead of 10/20/1948.  Thank you.