My client is the executor of her brother’s estate. Her brother did not leave a named beneficiary; his estate is the beneficiary of the plan. The executor would like to liquidate the stock and rollover the proceeds to an inherited IRA in the estate via a trustee to trustee transfer. We are being told that since the estate is a non-spouse beneficiary the plan will not allow for this option. The custodian of the plan has presented us with two options: continue to receive RMDs over the remaining life of the decedent (the brother at DOD was beyond his required beginning date) or take a lump sum distribution of the plan assets which will have an unfavorable tax consequence for the estate and the beneficiaries. Is the plan able to place these restrictions on the distribution? If so, does the custodian and plan administrator have an obligation to the executor to provide a written explanation and citation of plan documents that form the basis of this policy? I have not been able to locate any relief provision in the qualified plan regulations published by the IRS for this circumstance.