RMD related

[Jakyasar]

Hi

DB plan effective 1/1/2021.

Owner was 73 years old in 2021 and the vesting was 100% as of 12/31/2021.

Plan was not signed till July 2022.

So, when is the RMD due?

Thanks

[John Feldt ERPA CPC QPA]

Assuming more than 5% owner, the payment of the 12/31/2021 vested accrued benefit should have commenced once the document was signed, or shortly thereafter in 2022.