Audit Guidelines on Missing Participants and RMDs

The IRS releases audit guidelines on missing participants and required minimum distributions.

Document Excerpt

This memorandum directs EP examiners not to challenge a 403(b) plan as failing to satisfy the required minimum distribution (RMD) standards under Internal Revenue Code (IRC) § 403(b)(10) in the circumstances set forth below. This memo addresses only the application of IRC § 403(b)(10) to certain circumstances involving a 403(b) plan’s actions related to a benefit of a participant or beneficiary whom the plan is unable to locate and does not address the application of any other requirements or other applicable law, including Title I of ERISA. This is not a pronouncement of law and is not subject to use, citation, or reliance as such. Nothing herein shall affect the operation of any other provision of the IRC, Treasury Regulations, or guidance thereunder.


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