Required Minimum Distributions (RMDs)

If plan document includes text of IRS code must follow document unless amended
If plan document references IRS code must follow CARES Act changes to code
Voluntary withholding applies if RMD is distributed to avoid plan sponsor penalty
Examples: John’s Required Beginning Date is April 1, 2021
- The RMD due April 1, 2021 which is for 2020 is waived
- Next RMD required by December 31, 2021
- John’s Required Beginning Date is April 1, 2020
- The RMD due April 1, 2020 is waived since it is due in 2020 for 2019
- The RMD due December 31, 2020 is waived since it is due in 2020