RMD Notices
With RMDs being suspended for 2009 are custodians still required to send out notices to clients by January 31st advising they are in RMD status?
The Sec 401(a)(9) regulations provide for reporting. The method of reporting was given in IRS Notice 2002-27 (clarified by Notice 2003-3). One of the methods of reporting was to say that the custodian could calculate the distribution upon request.
I think that custodians will have to notify those over 70.5 that no RMD is required.
The IRS sent out this related Notice last week
Permalink Submitted by Jose Morales on Thu, 2009-01-08 16:59
My best guess is that since there is no RMD to notify the client of there is no need for a notice. However, we have this notice built into the Fair Market Value statement we give to our clients every year and since this legislative change occurred so late in the year we have no time to remove the RMD calculation or message. We will be sending a letter to all of our clients who would have had to take an RMD to make them aware of the legislative change.