Any relief for missed RMDs for a non-eligible designated beneficiary of a DB plan participant?

[David Peckham]

Notice 2023-54 provides relief for missed 2021, 2022 and 2023 RMDs for a non-eligible designated beneficiary of an IRA or DC plan. What about a missed RMD for a non-eligible designated beneficiary of a DB plan participant?

[Lou S.]

I think relief is offered through VCP in these situations. I'd have to go back and check the latest IRS Rev Proc on EPCRS but I'm pretty sure the correction under VCP that would most likely be approved is making the missed payments with interest and request a waiver of the excise taxes with the submission.

But I don't think DB RMDs are eligible for Self Correction. I'd like to be wrong on that so if someone has something where this would be allowed as a Self Correction, that would be great if they had a citation.