Clarification of the Legislative Changes Made for RMDs

Experts from Groom Law Group and Cammack Retirement Group answer questions concerning retirement plan administration and regulations.

“With the avalanche of guidance on required minimum distributions lately, from the SECURE Act to the CARES Act and beyond, I am now thoroughly confused as to when minimum distributions are due, and for whom. Without confusing me, can the Experts provide a simple response in this regard?”

Stacey Bradford, Charles Filips, David Levine and David Powell, with Groom Law Group, and Michael A. Webb, vice president, Retirement Plan Services, Cammack Retirement Group, answer:

We’ll certainly give it a try! It is true that the array of guidance on required minimum distributions (RMDs) issued just since last December is probably dizzying to most plan sponsors. Since you asked for a simpler explanation, here is a GENERAL, non-exhaustive, year-by-year guide to minimum distributions for 2019, 2020, and 2021, which should probably get your through most of your basic RMD scenarios, as follows:

2019: If I had already turned age 70.5 AND retired prior to 2019, an RMD would have been due for me by 12/31/2019; neither the Setting Every Community Up for Retirement Enhancement (SECURE) Act nor the Cornoavirus Aid, Relief, and Economic Security (CARES) Act changed this. However, if I was retired and turned age 70.5 in 2019, or was older than 70.5 and retired in 2019, my first RMD is not due until 12/31/2021, since all 2020 RMDs were waived by the CARES Act. If I accidentally took an RMD in 2020, since I was not aware of the waiver, I have until August 31 to roll that distribution back into the retirement plan from which I took it out (if that plan permits) or any other retirement plan/IRA. If I took the RMD in 2019, though, it remains an RMD for 2019 and cannot be rolled over.

2020: If I had already turned age 70.5 AND retired prior to 2019, my regular RMD that would have been due in 2020 is waived and my next RMD would not be due until 12/31/2021. If I turned age 70.5 prior to 2020, but retired in 2020, my initial RMD would be due by 12/31/2021. My initial RMD would normally have been due on 4/1/2021, but the CARES Act waived it. If I was a retiree who turned age 70.5 in 2020, my first RMD would not be required until 4/1/2022 at the earliest, since the SECURE Act changed my required beginning date to 4/1 of the year following the year in which I turn 72 (or retire, if later).

2021: If I had already tuned age 70.5 AND retired prior to 2019, my regular RMD would be due 12/31/2021. If I turned age 70.5 prior to 2020, but retire in 2021, my initial RMD would be due 4/1/2022, with an additional RMD due by 12/31/2022. Otherwise, age 70.5 is no longer relevant to my RMD, as the new age is 72. Thus, if I turn age 72 in 2021 and am already retired, my initial RMD would be due by 4/1/2022, with a second RMD due by 12/32/2022.

Hopefully this helps. Thank you for your question.


NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.

Do YOU have a question for the Experts? If so, we would love to hear from you! Simply forward your question to with Subject: Ask the Experts, and the Experts will do their best to answer your question in a future Ask the Experts column.