Are 72t distributions exempt from having to w/draw in 2020 under Section 2202 of Cares Act?

Here’s the crux: RMDs may be discontinued in 2020 (only) without penalty. Can 72t distributions also get that same treatment? (pre-59-1/2 start dates)?



No. A 72t distribution must still be made to avoid busting the plan, and the CARES Act did not exempt them. They are not RMDs and the plan was created voluntarily, unlike RMDs which were involuntary until the CARES Act made them voluntary for 2020. Further, all 72t plans have been completed before RMD age.

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