Under IRS Publication 590-B, three longevity tables are used for Required Minimum Distributions (RMDs): the Uniform Lifetime Table, the Single Life Expectancy Table, and the Joint and Last Survivor Expectancy Table. The factors in these tables are technically called Applicable Distribution Periods (ADPs).
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The additional complexity engendered by the SECURE Act of 2019 calls for greater vigilance on the part of financial advisors when it comes to tracking Required Minimum Distributions (RMDs). The introduction of the 10-year rule and the establishment of Eligible Designated Beneficiaries (EDBs) created additional intricacy to RMDs.
The SECURE Act of 2019 increased the complexity of administering retirement plans for clients. Financial advisors are responsible to track the setup, investment, and distribution of these important client resources.
The SECURE Act of 2019 established Required Minimum Distribution (RMD) rules for Eligible Designated Beneficiaries (EDBs) who may extend their distribution period for inherited retirement plans. Financial advisors have a significant responsibility to assure that client retirement accounts are properly set up to reflect the EDB exceptions.
Under the SECURE Act (2019) , beneficiary designations took on added importance because the SECURE Act introduced a 10-Year Rule wherein account custodians must distribute the total amount of the retirement account within ten years.
Non-designated beneficiaries (charities, estates, and non-see-through trusts) may have only five years to distribute the account if the participant died before his or her Required Beginning Date (the 5-Year Rule). Under the new SECURE Act of 2019 rules, Required Minimum Distributions (RMDs) for beneficiaries inherited after 2019 depend upon the date of death of the Participant.
We added a sixth option in Step 1 to accommodate the 10-Year Rule, specifically, the “Successor Beneficiary” option. We now designate the Participant as the “Primary Beneficiary.” All follow-on beneficiaries are “Successor Beneficiaries.” A Non-Designated Beneficiary is an estate, charity, or non-see-through trust. None of these entities are natural persons.
The 2001 Required Minimum Distribution (RMD) Rules for Non-designated Beneficiaries were minimally affected by the SECURE Act of 2019. The change from 70-1/2 to 72 years of age for RMDs indirectly caused the Required Beginning Date (RBD) to slip slightly. If the participant died before his or her RBD, the custodian must distribute the account to the beneficiary using the 5-Year Rule. The SECURE Act of 2019 dramatically altered the rules for Required Minimum Distributions (RMDs) for designated beneficiaries. The distribution of an RMD to a designated beneficiary or a successor beneficiary now depends upon the date of death of the participant.
Required minimum distributions (RMDs) for spouses took a slightly new turn under the SECURE Act of 2019. The Required Beginning Date (RBD) was changed to April 1 of the year after the participant would have reached age 72. The RBD age for the past 44 years was 70-1/2.
If the participant died before his or her RBD... The SECURE Act of 2019 introduced a new term “Eligible Designated Beneficiary.” The Act established a 10-Year Rule as the maximum payout period for inherited retirement accounts that were inherited from participants dying after 12/31/2019, with a few exceptions. The exceptions apply to Eligible Designated Beneficiaries (EDBs), defined as follows:
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