Client is age 81, still an active EMT volunteer and participating in a LOSAP (Length of Service Award Program). He can only take distributions under clearly defined circumstances, RMD’s not mentioned in the program description as being one of them. Can that be taken to mean he is not (and has not been) subject to RMD’s even though he is otherwise well past his RBD (for his TIRA’s)? Your response would be greatly appreciated.