First RMD was 2020, when is 2021 due?

Former Employee left in 2019,turned 70.5 in 2020.  Her first RMD was for 2020, but that was suspended.  Initially, she needed to take that one by 4/1/21.

But since she didn't have to take it, the 2021 RMD will be her "first."  Does she have until 4/1/22?  Or is is due by 12/31/21?

If the employee turned 70.5 in 2020, then their RBD is 4/1 following the year they turn 72, under the SECURE Act.

And to apply C.B. Zeller’s guidance, you might prefer to see the participant’s birthdate.

If one knows only that the participant turned 70½ in 2020, in which year will the participant reach age 72?

An individual born after June 30, 1949 and before January 1, 1950 would turn 70½ in 2020 and 72 in 2021.

An individual born after December 31, 1949 and before July 1, 1950 would turn 70½ in 2020 and 72 in 2022.

To address the original question of "How does the CARES Act RMD waiver affect a participant who would have been required to commence distributions by 4/1/2021," this is addressed in Notice 2020-51. 

Quote

Q-5. How does § 401(a)(9)(I) impact an employee who has a required beginning date of April 1, 2021?

A-5. Section 401(a)(9)(I) waives the RMD for 2020 regardless of whether the employee’s required beginning date is April 1, 2021. Thus, for example, if an employee who is not a 5% owner attained age 70½ before January 1, 2020, and retires in the 2020 calendar year, that employee’s required beginning date is April 1, 2021. Pursuant to § 401(a)(9)(I), the employee is not required to receive an RMD for 2020 before April 1, 2021, but must still receive the RMD for the 2021 calendar year by December 31, 2021. If the employee receives a distribution during 2021, then under the rules of § 1.402(c)-2, Q&A-7, that distribution is an RMD for the 2021 calendar year to the extent the total RMD for 2021 has not been satisfied even if the distribution is made on or before April 1, 2021, and accordingly, is not an eligible rollover distribution pursuant to § 402(c)(4)(B). However, to the extent the RMD for 2021 has been satisfied, subsequent amounts distributed in 2021 that would otherwise not be eligible rollover distributions pursuant to § 402(c)(4)(A) and § 1.402(c)-2, Q&A-5, may be rolled over consistent with the rollover guidance provided in section III.B.2 of this notice.

Thanks, all.