Minimum Distributions for Missing Participants and Beneficiaries of Retirement Plans

December 6, 2017

Employee Plans Examinations issued a field directive to all exam agents on missing participants, beneficiaries and the required minimum distributions (RMD) standards under Internal Revenue Code Section 401(a)(9). The memo enhances EP’s enforcement of RMDs, but doesn’t address the application of any other qualification requirements or other applicable law including Title 1 of ERISA.

The memo directs EP examiners not to challenge a qualified plan for its failure to commence or make an RMD to a missing participant or beneficiary if the plan has taken the following steps:

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