Can the new minimum distribution rules be relied upon for someone whose RBD is 4/1/2001 (i.e. the first RMD for the 2000 DCY)? I understand that the model amendment must be adopted beforehand. I am pretty sure I know the answer, but want confirmation.

Mr X, see 2001-10 IRB. Minimums for calendar year 2000 taken by April 1, 2001 cannot rely on the new rules.