Turned 72 in 2020 – RMD by Apr?

Submitted by brcwm on Thu, 2021-03-18 13:18

I thought I had all the Secure / Cares Act rules covered, but I’m second guessing myself on this one. Client turned 72 in 2020, with RMDs waived in 2020, do they need to take their first one by April 2021? Or, do they get to wait to Apr 2022?

I saw this article: https://www.cnbc.com/2021/03/01/required-minimum-distributions-on-retirement-plans-are-back.html
Especially this part (below) makes it seem they need to take their 2020 RMD by April 1st this year?

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• Who has to take RMDs? The SECURE Act of 2019 raised the age when RMDs must begin to 72, from 70½, and there is discussion in Congress about extending it still further. If you turned 70½ in 2019, however, you were required to take the first RMD by April 1, 2020.

With the waiving of the RMD last year, the deadline is now April 1 this year for those individuals. Retirees who turn 72 this year can take the distribution at any point in the year or even delay it until April 1, 2022.
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Submitted by brcwm on Thu, 2021-03-18 13:43

Is this correctly stated? Born on or after July 1, 1949
Not 70.5 by Jan 1, 2020
Falls under Secure Act – RMD required the year they turn 72
Does not have any waiver of RMDs, because they are not under RMD rules
Their first RMDs will now have to be out of the account by either April 1, 2022 (if age 72 in 2021) or by April 1, 2023 (if age 72 in 2022)
  Born Between July 1, 1948 and June 30, 1949
Reached 70.5 in 2019
Secure Act age 72 rule do not apply
Required to take RMD by April 2020
QUESTION: If client postponed RMDs (did not take in 2019), and planned to take by April 2020, did those RMDs get waived by Cares?
 Born on or before June 30, 1948
Already started taking RMDs in 2019, waived normally in 2020
Secure Act did not apply
Cares Act RMD waiver applied

Submitted by Alan - IRA critic on Thu, 2021-03-18 15:26

The listings above are correct. With respect to the question in Group 2, the CARES Act did waive 2019 RMDs for those with a 4/1/2020 RBD to the extent the 2019 RMD was not distributed in 2019. Therefore, this client had both the 2019 and 2020 RMDs waived by CARES. The 2021 RMD is due by 12/31/2021 using the 12/31/2020 balance. No April deadlines exist for client.
However, in your first post the last statement is incorrect. The RBD was not changed from 4/2020 to 4/2021, and in fact no one has a 4/1/2021 RBD because 2020 was not an RMD distribution year for anyone.

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