pensiongeek Posted August 18 Posted August 18 I have a DB plan where the plan effective date is for 2024, providing a vested benefit accrual as of 12/31/2024, but the plan did not fund until August 2025. The RBD for the participant/owner was 4/1/2025. Did she miss her first RMD even though there were no assets in the plan to take an RMD from? Or maybe I am over thinking it. This RMD is mute because it is for 2024 which is based on a 2023 accrued balance that did not exist? Maybe her first RMD is actually due by 12/31/2025 for 2025 plan year based on 2024 accrued balance.
CuseFan Posted August 19 Posted August 19 This is from pre-approved plan document. 2024 is the first distribution calendar year so I think the vested accrued benefit as of 12/31/2024 needed to commence at 4/1/2025, which as you note creates an issue. Maybe someone else sees it differently. (2) Amount Required to be Distributed by Required Beginning Date and Later Payment Intervals. The amount that must be distributed on or before the Participant's Required Beginning Date (or, if the Participant dies before distributions begin, the date distributions are required to begin under Subsection (b)(2)(i) or (ii)) is the payment that is required for one payment interval. The second payment need not be made until the end of the next payment interval even if that payment interval ends in the next calendar year. All of the Participant's benefit accruals as of the last day of the first distribution calendar year will be included in the calculation of the amount of the annuity payments for payment intervals ending on or after the Participant's Required Beginning Date. (3) Additional Accruals After First Distribution Calendar Year. Any additional benefits accruing to the Participant in a calendar year after the first distribution calendar year will be distributed beginning with the first payment interval ending in the calendar year immediately following the calendar year in which such benefit accrues. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
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