13 pages. "The Applicability Date should be delayed.... Plans should have flexibility as to spouses already receiving RMDs.... Election rule should not depend on whether participant died before the RBD.... Final regulations should clarify the treatment of a new spouse of the spouse.... Clarify implications of a Roth conversion after RMDs begin.... Provide reasonable rules for alternate payees with designated Roth accounts.... Clarify that QPDAs, in-plan annuities, and purchase of DB annuities are eligible.... Allow plan to rely on information from participant or insurer."  MORE >>