Ineligible Designated Beneficiary

A daughter inherits a governmental plan sponsored by state ie. ORP on his death 3/7/2020. He was 88, she age 53. Secure Act Language specifies for effective dates will take place 12/31/2019 except (However, participants of plans pursuant to a collective bargaining agreement (Union Plan) and participants of governmental plans such as 457(B) and Thrift plans sponsored by Federal, State, and Local governments and agencies can enjoy the old rules until January 1, 2022.

Does this mean the 10 clock starts on January 1, 2022?



No, it means that the pre Secure rules apply in this case, and there is no 10 year rule. There is no year of death RMD because 2020 RMDs are waived, and daughter’s first life expectancy RMD will be for 2021 based on her age attained on her birthday in 2021.

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