401K RMD if still employed by employer

I have a client turning 72 this December 2021. He is still working with two different employers and each have a 401k plan. Does he have to take an RMD either this year or by April 1, 2022 if he is still employed by both firms?



If he is still employed by these employers on 1/1/2022, there is no 2021 RMD required unless client is a >5% owner of the employer. A few plans may require ALL employees to start RMDs at 72 even while still working, but these are plan RMDs and not statutory RMDs, and therefore these plan RMDs can be rolled over to an IRA. If client is not considered to be working enough hours to qualify as still employed for RMD purposes, is a >5% owner, or retires before 2022, his 2021 RMD would not be due until 4/1/2022.

Thank you very much!!!!

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