RMD Procedures -- Default Distribution For.

A client maintains a defined benefit plan and has requested help in complying with RMD rules.

If a plan participant cannot be located or fails to cooperate in completing and returning a distribution form, can the plan's administrator commence paying distributions in a default form based on file information as to marital status and date of birth?

What can be done to correct the default RMD form if the date of birth and/or marital status turn out to be inaccurate after distributions commence?

If the plan does not have marital status information about a participant to whom RMDs are payable, can the plan presume that the participant is married or single and commence RMDs based on a presumed marital status?

Is this a terminated non-owner participant who attained the RMD age?

If an active participant, what does the document say about non-owners getting RMD's? They can be possibly deferred and getting AE increase, all depends what the document says.

Jakyasar, 

This is a non-owner participant who attained the applicable RMD age. It would be limited to deferred vesteds since the RBD for actives is delayed until after actual retirement.

I thought DB plans had to start payments by RBD regardless of employment status. Did that change or am I misremembering?

I would think you would have to start payment in the normal form of benefit. I'm not sure what the procedures are for a participant who has an unknown marital status, you an check the plan document or talk to your document provider to see if it is addressed. I image a reasonable good faith assumption could be made but if your assumptions result in underpayments, you will likely have to made back payments plus interest if/when you get corrected data.

Has the client checked old beneficiary designation forms or reviewed it's medical from when they were active, marital status might be there?

Have you confirmed that the missing ex-employee is still alive?  Be creative in how you search.

2 hours ago, Lou S. said:

I thought DB plans had to start payments by RBD regardless of employment status. Did that change or am I misremembering?

I would think you would have to start payment in the normal form of benefit. I'm not sure what the procedures are for a participant who has an unknown marital status, you an check the plan document or talk to your document provider to see if it is addressed. I image a reasonable good faith assumption could be made but if your assumptions result in underpayments, you will likely have to made back payments plus interest if/when you get corrected data.

Has the client checked old beneficiary designation forms or reviewed it's medical from when they were active, marital status might be there?

If a non-owner is still employed, plan document states it and plan provides AE increase, RMD can be deferred until retirement/termination/death

Thank you, everyone, for your thoughtful insights and suggestions. To answer everyone's questions: (1) the RBD for all types of qualified plans, other than church or governmental plans, is the later of attainment of the applicable age or retirement (except for 5% owners). (2) the plan has a separate missing participant and beneficiary procedure and it requires verification that the recipient remains alive, and requires that such items as benefit enrollment, beneficiary designation and other documents be checked to attempt to ascertain the recipient's marital status and date of birth. The problem, for any intended recipient, is whether such marital status has changed as well as whether beneficiary designations have changed in the interim. Since the terms of the policy apply only to terminated employees, attainment of the applicable age is what will likely trigger the RBD for that individual.