RMD after plan termination

Fiscal cash balance plan. 6/30 year end.

Plan terminated 6/30/2023.

Spouse of owner participant is required to get first RMD due to becoming 100% vested as of 6/30/2023+attaining age 73. He has only 3 YOP so was vested in year 3 which ended on 6/30/2023.

There is a possibility that the distribution will be postponed to 2024 as there is a contribution due.

1. When in the first RMD due 12/31/2023 or 4/1/2024 (or prior if distribution done earlier)

2. If due 12/31/2023, because the plan is in termination status, can the RMD be calculated based on account balance?

Thanks

When's the RBD?  Did he JUST turn 73 or did he JUST become vested in the accrued benefit?  (Making sure the RBD hasn't already passed but with a $0 payment due earlier due to it being a year he was still nonvested)

He turned 73 in 2023 and became 100% vested in 2023.

RBD is one the questions I am asking for.

So he turned 72 last year which means his RBD was 4/1/23, right?  So his minimum at that point was still zero due to nonvestedness.  Now we have an increase in the vested accrued benefit, which typically you have within 12 months to adjust to the payment stream, I think.

Since he had a 2022 RMD that was not made due to 0% vesting, I believe he will need to take his 2023 RMD by 12/31/2023.

To use the DC method for CB Plan I think he needs to elect a lump sum in which case you can use the DC method on the amount being distributed which is not eligible for rollover.

But you might get different opinions from different people as I don't believe this specific fact pattern is covered perfectly in the regs and could be open to other interpretations.

I think I agree with the 12/31/2023 date.

As to how to get the RMD in a terminated plan and without any election is some something I am not sure

Will continue researching. So unnecessarily complicated.

Read the plan. You likely need to commence at a minimum the 50% J&S annuity (make sure there is a new annuity starting date for the plan termination distributions and the J&S is not locked in). If the plan has in-service distribution provision then person could elect lump sum, so part RMD and part RO-eligible using account balance method. BUT, if this not done as part of plan termination distributions (i.e., paid earlier) then you may have to satisfy the restricted employee 110% funding threshold requirements. The plan termination wrinkle really isn't the complicating factor, you can continue normal administration, it just potentially accelerates a final distribution. So I suggest you ignore the plan termination for now, administer this as you would an ongoing plan and then do whatever final RMD and RO split you need to do when the termination distributions happen.