72(t) timing

Hello,

I have a client who started a 72(t)/SEPP arrangement in 2017. The IRA was open in August of 2017, and he took an annual payment in September. He has since taken four subsequent annual payments. He is now over 59.5. Will he have unfettered access to his IRA in January of 2022, or do we need to wait until Spetember of 2022 to meet the five year requirement?



The plan “modification date” is 5 years from the date of the first SEPP distribution in Sept, 2017. Since he has taken his 5 equal annual distributions (2017-2021), he should not take another distribution until after the modification date since this is a 5 year plan, which means waiting until Sept 2022. A couple days should be added to the 5 year anniversary of his first distribution for margin of error. 

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