RMD

403(b) participant with her current employer; turning 72 next year & currently working part-time.
Ineligible to participate in the plan due to P/T status.

Question
Does being ineligible (to participate in the plan) disqualify the participant from using the “still working” RMD exception?



Participation in the plan is immaterial with respect to the “still working” exception. However, if hours are insufficient the plan provisions might treat the person as retired. Participant has a year to reconcile this since there will be no RMD for 2023 due to the Secure Act 2.0 increase in the starting RMD age to 73.

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