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The SECURE Act, RMDs, and Beneficiaries -- Another Wrinkle
Natalie Choate, via MorningstarLink to more items from this source
[Guidance Overview]
Dec. 9, 2021

"SECURE's legacy exception applies to the designated beneficiary of a participant who died prior to SECURE's effective date (Jan. 1, 2020). However, it ceases to apply upon the death of 'such employee's designated beneficiary who dies after such date.' ... Based on SECURE's language, it appears that the life expectancy payout of a pre-2020 decedent's account is legacied 'forever' if the original account owner and his/her designated beneficiary both died prior to 2020:"

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