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Confirming an RMD Took Place

The Treasury regulations indicate a participant with multiple 403(b) accounts can aggregate them to determine the required minimum distribution (RMD) amount and then take the RMD from a single account (similar to IRAs). A person has worked for two different (unrelated) non-profit organizations and participated in a 403(b) plan at each organization (let's just say 403(b) plan X and 403(b) plan Y). This person wants to take the combined balance for Plan X and Plan Y to calculate the RMD and then distribute the total RMD from Plan X (nothing would be distributed from Plan Y).


Q. Would the sponsor for Plan Y need to confirm the RMD had taken place and are there any additional steps the plan sponsor should take if unable to confirm the RMD was processed?

A. No additional steps needed if the participant indicates on their distribution (RMD) form that the minimum is being taken from the "XXXX 403(b) Plan." The provider or the TPA will in most cases have this type of form for the sign off.

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