IRS Revamps Required Minimum Distribution Rules
The IRS is proposing new regulations related to RMDs for all qualified plans.
On February 24, 2022, the IRS proposed new regulations related to the required minimum distribution (RMD) from qualified plans, including governmental plans, largely as to reflect amendments made to section 401(a)(9) by sections 114 and 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on December 20, 2019. There are three key take-aways for governmental plan sponsors.
1. The required beginning date has changed from age 70 1/2 to age 72. The proposed regulations for defined benefit plans do not, however, make changes to when actuarial increases must apply (that continues to be at age 70½).
2. Compliance with the new regulations would be required for 2022.
3. The new 10-year payment rule to beneficiaries will add more complexity to the minimum required distribution process for plans, including that beneficiaries of participants who die after a participant has commenced their MRDs must receive annual payments under the life expectancy rule (“at least as rapidly”) AND receive all amounts within the 10-year period.
The IRS is accepting comments on the proposed regulations until May 25, 2022. Commenters are strongly encouraged to submit public comments electronically. Submit electronic submissions via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG-105954-20) by following the online instructions for submitting comments.
More information, including the text of the proposed changes, is available in the Federal Register.
The Groom Law Group has written an excellent synopsis that they posted on their website on March 1, 2022. The document is titled "IRS Revamps Minimum Required Distribution Rules."
1. The required beginning date has changed from age 70 1/2 to age 72. The proposed regulations for defined benefit plans do not, however, make changes to when actuarial increases must apply (that continues to be at age 70½).
2. Compliance with the new regulations would be required for 2022.
3. The new 10-year payment rule to beneficiaries will add more complexity to the minimum required distribution process for plans, including that beneficiaries of participants who die after a participant has commenced their MRDs must receive annual payments under the life expectancy rule (“at least as rapidly”) AND receive all amounts within the 10-year period.
The IRS is accepting comments on the proposed regulations until May 25, 2022. Commenters are strongly encouraged to submit public comments electronically. Submit electronic submissions via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG-105954-20) by following the online instructions for submitting comments.
More information, including the text of the proposed changes, is available in the Federal Register.
The Groom Law Group has written an excellent synopsis that they posted on their website on March 1, 2022. The document is titled "IRS Revamps Minimum Required Distribution Rules."