RMD Rules under CARES Act

I have seen some discrepancy in summaries of the RMD rules for 2020 under the CARES Act. Section 2203 (a)(I)(ii) says that the RMD rules are suspended for 2020. Section 2203(a)(I)(ii) adds what I thought was a special rule/clarification that required beginning dates in 2020 are effectively suspended. 

But, I have seen summaries that imply that the RMD suspension ONLY applies for distributions for those participants with required beginning dates in 2020. 

So, which is it: are all RMDs suspended in 2020 or only those for required beginning dates in 2020?

All RMDs suspended for 2020

1 minute ago, RatherBeGolfing said:

All RMDs suspended for 2020

That is what I thought too. 

1 hour ago, RatherBeGolfing said:

All RMDs suspended for 2020

From individual account plans (401(k), PSP, IRA, etc.).

Not DB plans.

23 minutes ago, Mike Preston said:

From individual account plans (401(k), PSP, IRA, etc.).

Not DB plans.

Yes- understood. Thanks!!

33 minutes ago, Mike Preston said:

From individual account plans (401(k), PSP, IRA, etc.).

Not DB plans.

Good thing we have an actually here to keep reminding us about those darn DB plans! ?

35 minutes ago, Mike Preston said:

Not DB plans.

I always try to forget about those pesky DBs...

2 hours ago, chibenefits said:

I have seen some discrepancy in summaries of the RMD rules for 2020 under the CARES Act. Section 2203 (a)(I)(ii) says that the RMD rules are suspended for 2020. Section 2203(a)(I)(ii) adds what I thought was a special rule/clarification that required beginning dates in 2020 are effectively suspended. 

But, I have seen summaries that imply that the RMD suspension ONLY applies for distributions for those participants with required beginning dates in 2020. 

So, which is it: are all RMDs suspended in 2020 or only those for required beginning dates in 2020?

Everyone is right; that language about required beginning dates in 2020 was to take care of delayed 2019 first time RMDs that elected to delay their RBD to 2020.  That's how those were incorporated into the rule.