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As per the revised age for participants to receive RMD for those who reach age 72 after Dec. 31, 2022 and age 73 before Jan. 1, 2033, the RMD age would be 73. For terminating plans how should the RMD be handled? 

1) Is the RMD processed based on the status? if the participant is terminated or retired should the RMD be processed? though they can be employed by the acquiring company or can the participant defer it. 

2) The forced distribution to the unresponsive participants I believe the RMD should be processed first and then the full distribution should be processed.  What in case if the RMD is not processed what would be the repercussion. 

Thank you. 

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  • 3 weeks later...
18 hours ago, Lou S. said:

If the participant is RMD age, I have always processed the rollover first in terminating plans.

Rollover first? Or RMD first? Because the RMD has to come out if the participant will reach RMD age during the Distribution Calendar Year.

William C. Presson, ERPA, QPA, QKA
C 205.994.4070


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Maybe too late: the plan is not required to adopt the age 72/73 changes.  It makes a difference in the portion subject to rollover.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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