The ‘‘Coronavirus Aid, Relief, and Economic Security Act’’, referred to as the ‘‘CARES Act’’, suspended the age 70-1/2 or age 72 “minimum required distribution” (“MRD” or “RMD”) otherwise required to be paid in or for the 2020 calendar year, for defined contribution plans (e.g., profit sharing, money purchase, 401k and 403b plans) but not defined benefit and cash balance pension plans. It is unclear whether the MRD suspension is mandatory or optional – and if optional, whether it is the employer’s or individual’s option. There is speculation that a 2020 MRD that was taken earlier this year may be allowed to be rolled-over into an IRA or the employer’s plan, but no such guidance has been issued (yet). To the contrary, it is possible that any distribution in 2020 which otherwise would be a MRD will be ineligible to be rolled-over into an IRA or another employer’s plan. ACSI (www.acsi-ny.com or mbrand@acsi-ny.com) is monitoring further developments regarding the MRD rules.
