RMD Rollover and Aggregation Rules: Today’s Slott Report Mailbag

Thursday, January 09, 2025

By Ian Berger, JD
IRA Analyst

Question:

I am planning for a required minimum distribution (RMD) from both my IRA and 403(b) plan for 2026, my first RMD year. I am in the third year of a 10-year period in which I am rolling over 10% of my 403(b) funds each year to my IRA as a way to consolidate. This is per my 403(b) contract. The funds get rolled over in September each year.

In 2026, do I need to take my RMD before the 10% rollover on the balance of my 403(b)? Are there regulations or just preference as to when I should take the RMD?

Claudia

Answer:

Hi Claudia,

Yes, starting in 2026, you will need to take your RMD from the 403(b) plan before doing the rollover to the IRA. That’s because the first dollars paid out of the 403(b) in any RMD year are considered the RMD, and RMDs cannot be rolled over. There is no rule requiring you to take the RMD at any particular time during the year, as long as it is taken before your rollover in September.

Question:

I believe that my RMD can be taken from any account to satisfy the total RMD, but does that apply to different types as accounts such as an IRA and a 401(k)? A related question: Can I use a qualified charitable distribution (QCD) from an IRA to satisfy the RMD for both my IRA and 401(k)?

Thanks for any insights you can provide.

John

Answer:

Hi John,

You can satisfy the total RMDs of all of your IRAs (and any SEP or SIMPLE IRA) from any IRA (or SEP or SIMPLE). But RMDs from IRAs and retirement plans, like 401(k)s, must be taken separately. Meanwhile, a QCD can only be used to satisfy an IRA RMD.

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