Additional complexities arise if benefits are already being paid.
From an estate planning point of view, it is important to know when a participant's RBD occurs. A qualified plan sponsor appears to have three alternative ways to respond to the new RBD definition. In such a case, regardless of whether the employee elects to receive benefit payments while continuing employment, the participant's RBD will be April 1 following the calendar year of retirement both for minimum payment and income tax purposes. In this case, the participant's RBD will not occur until the April 1 after retirement. The delayed application of such a plan amendment is due to Prop.