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November 30, 2009 Required Minimum Distribution (RMD) Deadline

  
  
  

We recently discussed 2009 Required Minimum Distributions (RMDs) and how, as a result of the economic downturn, the requirement to take 2009 RMDs was waived. A participant that has already received a 2009 RMD has until the later of November 30, 2009 or 60 days after the date the distribution was received to roll it over. The waiver created many other administrative issues that need to be addressed, such as:

  • Can I still pay a required minimum distribution if the participant would like to take it?
  • Do participants have to opt out or do they opt in?
  • Are 2009 RMD amounts eligible for a rollover?
  • What about the plan document?

November 30, 2009 Is Deadline for Plan Sponsors to Finalize 2009 Required Minimum Distribution Procedures provides a plan sponsor action item list for the November 30, 2009 deadline:

  • Make Any Remaining Decisions Regarding RMD Procedures
  • Review 2009 RMD Procedures for Compliance with IRS Guidance
  • Plan Amendment Deadlines (Employer-Sponsored Retirement Plans and IRAs)

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2012 IRS Pension Plan Limits

401(k) Deferral Limit - $17,000

Annual Additions Limit - $50,000

Maximum Compensation Limit - $250,000

Catch-Up Contribution Limit - $5,500

Highly Compensated Employee - $115,000

ESOP 5-Year Distribution Threshold - $1,015,000

ESOP Additional Year Threshold - $200,000

2012 Pension Plan Limits

1989 - 2012 Plan Limits