If a non-owner employee is 70.5 and elects to waive the RMD for 1998, is there a minimum number of hours the employee has to work before he/she has the right to waive the RMD? In other words, does the waiver apply to part-time employees as well as full-time employees?

My understanding is that the 70 1/2 distribution option is a protected right, and the employee must be given the option of receiving the 70 1/2 distribution or deferring it, regardless of how many hours the employee is working. This option can be eliminated only for employees who attain age 70 1/2 in or after a calendar year that begins after the later of December 31, 1998 or the adoption date of the amendment.