A SIMPLE IRA plan participant died in October of 2005 at the age of 38 prior to his RBD. The 12-31-2005 SIMPLE IRA account balance was only $540. His primary beneficiary was his former spouse. His contingent beneficiary was his daughter (and former spouses daughter) born in August 1997. The custodial agreement states that the legal termination of the participants marriage automatically revokes the fromer spouse as a beneficiary designation. Based on that it appears that the contingent beneificaiary daughter becomes the primary beneficiary. The custodian has not been notified of the participants death and there has been no changes to the titling of the account and no distributions since the participants death. It appears to me that the daughter (or her representative) should have made a required minimum distribution prior to 12/31/2006 in order to stretch the SIMPLE IRA over her lifetime (the custodial agreement allows stretching for non spouse beneficiaries). Could the daughter take both the 2006 and 2007 RMD in 2007 and then continue with the stretch going forward or does the fact that the 2006 RMD was not done in 2006 wipe out the lifetime stretch for the daughter? If the lifetime stretch was wiped out, does the daughter then have 5 years (2006-2011) over which to draw down the SIMPLE IRA plan balance?