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2009 RMD Waivers: IRS's Clarification and Transitional Relief
Deloitte via BenefitsLink
[Guidance Overview] Oct. 7, 2009
Excerpt: As adopted, the amendments must reflect the operation of the plan with respect to the 2009 RMD waiver (except for the period January 1 through November 30, as described above in the Transition Relief regarding Plan Compliance). The IRS provides two versions of a sample amendment: in one version the 2009 RMDs and Extended 2009 RMDs will be distributed unless the participant or beneficiary affirmatively elects otherwise, and in the other version the distributions will not be made unless the participant or beneficiary affirmatively elects otherwise. Direct rollovers of the 2009 RMDs and Extended 2009 RMDS are not offered under either ? although the sponsor can add provisions to provide a direct rollover of both, or only of the 2009 RMD.
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