RMD Start date - checking

I am born on 12/30/1950 and am more than 5% owner.

Is my RBD 4/1/2023?

Is my second RMD due 12/31/2023?

Thanks

@Jakyasar You have the correct dates.  Hopefully your RMDs due 2023 were paid to you in 2023.

The following chart is handy for looking at start dates.

.... assuming the Plan itself is/will be amended to recognize the new 72/73 ages.  There is no requirement to do so.

Aren't the deadlines for amending extended?

Yes. Presumably the plan is tracking its elections (on RMD treatment and other provisions) to incorporate into an eventual amendment by the deadline if it has not already adopted one.

The tax-law condition about a required beginning date is a no-later-than condition. Meeting § 401(a)(9) does not preclude an earlier required beginning date. A plan’s sponsor may set a younger age if it does not compel an involuntary distribution before the participant’s normal retirement age, and comports with other tax-qualification conditions.

Tax law recognizes a plan’s administration contrary to its current documents if that administration later becomes legitimated by a remedial amendment.

But what if a plan’s administrator doesn’t yet know what an anticipated amendment will be? And doesn’t know even what the plan’s sponsor intends for a later amendment?

(I recognize that getting this information often is about an employer talking within itself, at least for many single-employer plans. But to see an awkwardness that results from tax law’s remedial-amendment tolerance, let’s follow ERISA’s distinction between a plan’s sponsor and the plan’s administrator.)

Imagine a plan for which the current documents set a required beginning date in relation to age 70½. Imagine that the plan’s sponsor has not communicated to the plan’s administrator that the sponsor intends to amend the provision to refer to some other age. In those circumstances, the plan’s administrator might interpret 70½ to mean 72, 73, or 75 (as fits the particular participant), but also might interpret 70½ to mean 70½.

Some service providers have blithely assumed every plan’s sponsor intends to amend a plan to provide for a required beginning date’s age the latest age § 401(a)(9) permits. Perhaps that’s almost universally so.

But shouldn’t a service provider ask the question?

Even if it’s the ubiquitous “we assume you want x, unless your written instruction tells us otherwise.”

Or even, “we provide our service assuming your plan provides x. If your plan provides something else, you must administer your plan without relying on our service.”

@Peter Gulia is spot on.  Also, if the plan-required date is based on age 70-1/2, but the participant's RMD is 72 or 73 (according to the IRC), the payment (assuming a lump sum) is 100% rollable.