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We have a participant who terminated service in 2020. He is 75 years old and not a 5% owner (so he didn't have to take any RMDs in the past). I understand that he did not have to take the first RMD for 2020 due to the CARES Act Waiver. However, what is the date by which he had to take the 2021 RMD. Would it be 12/31/2021 or 4/1/2022?

 

Thanks.

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