I know there have been other discussions on this, but I want to make sure we are not missing anything. We have sent each RMD participant a notice regarding their RMD for 2009 and asked them to decide if they did or did not want to take their 2009 RMD.

If a plan has employees who did not take their RMD, are we required to attach the "default to discontinue 2009 RMD" amendment by 11/30 or is that just required if the employees wanted to roll over their RMDs?

My understanding from the Rev. Notice (which I have not read in a few weeks) is that amendments are not requried until 2011, but that a decision must be made now whether all receive MRDs unless they opt out, or only those who opt in receive MRDs. Then the eventual amendment mirrors the way it was done operationally.

The 11/30 date is the date by which earlier inadvertent MRDs can be rolled over even if the normal 60-day period has expired.