Eligible Designated Beneficiary

The SECURE Act changed RMDs for nonspouse beneficiaries to the 10 year rule, unless you're an eligible designated beneficiary (EDB). Other than a spouse, that's someone who is a minor child, disabled, chronically ill, or an individual not more than 10 years younger than the participant. We interpreted the last one to be someone younger, but not by more than 10 years. A client interprets that to also include any nonspouse beneficary who is older than the participant because they are 'not more than 10 years younger'. That would mean the 10 year rule only applies to a nonspouse more than 10 years younger than the participant (not including minor children). How have others interpreted this?

I agree with your client. The SECURE Act RMD rules were intended to eliminate "stretch" RMDs based on the life expectancy of a beneficiary who is far younger than the participant. If an individual who is older than the participant (and therefore not more than 10 years younger) is the beneficiary, they wouldn't be able to stretch the RMDs over a longer life expectancy either way.