RMD due date - confused

Hi

Checking for someone

DC plan - calendar

Joe DOB 12/1/1951 - when is first RMD due?

Mary DOB 10/1/1950 - when is first RMD due?

In both cases when is second RMD due?

Thanks

Assuming they are not currently employed or they are 5% owners...

Joe turns 72 in 2023 and under SECURE he was not 72 in 2022 and therefore did not have a 2022 RMD. Under SECURE 2.0 Joe does not turn 73 until 2024 and has a 2024 RMD with an RBD of 4/1/2025.   The 2nd RMD for 2025 would be due by 12/31/2025.

Mary turned 72 in 2022  (70 1/2 in 2021 after SECURE so no 2021 RMD) and under SECURE she had a 2022 RMD with an RBD of 4/1/2023. Under SECURE 2.0 she can not further delay her RMDs because they have begun and has 2nd RMD due for 2023 as of 12/31/2023.

If my math and effective dates are correct your first RMD "year" would be -

2019 (or earlier) if born before 7/1/1949 (70/12 rule)

2021 if born 7/1/1949 - 12/31/1949 (72 rule)

2022 if born in 1950 (72 rule)

2024 if born in 1951 (73 rule)

2035 if born in 1960 (75 rule)

Also 2020 CARES suspended DC and IRA RMDs, but not DB RMDs.

There were no "new*" RMDs for 2020 due to SECURE, 2023 for SECURE 2.0 and 2033-2034 also SECURE 2.0. *and by "new" I mean some one who didn't delay first RMD because they were not a 5% owner and were still employed.

Thank you for the great write up

A follow up question

Looks like Mary did not take the RMD by 4/1/2023.

Can she take it now with the actual 2023 RMD and also could this be under self-correction?

Thanks

The IRS website says "Some RMD failures may be eligible for self correction" it further goes on the say the participant excess tax can't be automatically waives, that is you need to pay it and request a refund. It goes on to say that under VCP you can ask for a waiver of the penalty.

I'm not sure which RMD failures are eligible for self correction and which are not. Given this is 1 participant who is being corrected in the same calendar year, my guess is the Plan would be eligible fore self correction, but I can't guarantee  that. You should check the current EPCRS Rev Proc.

https://www.irs.gov/retirement-plans/correcting-required-minimum-distribution-failures