We have received several client questions on the 2020 RMD waiver and would like to provide further information.
Required Minimum Distributions have been waived for 2020. This applies to all retirement accounts (except defined benefit plans) as well as to inherited IRAs. It also applies to any RMD that needed to be taken in 2020 – including those first time RMDs that were pushed from 2019 into 2020.
If you have already taken your RMD for 2020, you may be able to reverse it if done within 60 days. Return of funds to a retirement account within the 60 day window constitutes a rollover and there is a limit of one rollover every 365 days for any one IRA / Retirement Account owner (all retirement accounts are aggregated).
Please note that individuals who took their 2020 RMD earlier this year (beyond the 60 day rollover period) may still have an opportunity to reverse it. At this point, the CARES Act does not allow rollovers beyond 60 days, however, we will continue to look for further IRS guidance on the subject.
Inherited IRA RMDs already taken cannot be reversed.
Voluntary distributions are not affected and can still be taken. This includes Qualified Charitable Distributions for those IRA owners and Beneficiary IRA owners age 70 ½ or older.
Please contact your advisory team with your questions about this or any other aspect of the CARES Act benefits.