51. Timing and modes of distribution
Section 3. Required Beginning Date.
Publication 6165 — Defined Benefit Listing of Required Modifications and Information Package (LRM) · 2026-10-03 edition · updated 2026-10-04 · United States
The required beginning date of a participant with respect to a plan is (select one):
a. ( ) April 1 of the calendar year following the calendar in which the participant attains age
70½.t he Applicable Age.
b. ( ) April 1 of the calendar year following the calendar year in which the participant
attains age 70½, the Applicable Age, except that benefit distributions to a participant
(other than a 5-percent owner) with respect to benefits accrued after _____ (insert the
later of the adoption or effective date of an amendment to the plan that implements the
changes to the required beginning date of this paragraph) must commence by April 1
of the calendar year following the later of the calendar year in which the participant
attains age 70½ the Applicable Age or the calendar year in which the participant
retires.
(Note to reviewer: The above blank, referring to an amendment date, refers to 1997 changes to required beginning date determinations for non-5% owners. Under these changes, for a participant (other than a 5% owner) who attained age 70½ after a specifed
293 | Defined Benefit Plan LRM Package 08/2020 06/2026
year, relief was afforded from the applicable sections of IRC 401(a)(9). See Notice 97-75.)
(Option (c) below may be elected only if (i) it corresponds to an amendment previously made to
the plan pursuant to Treas. Reg. § 1.411(d)-4, Q&A-10(b), of the regulations or (ii) it does not
eliminate an age 70½ distribution option, as described in the preceding regulation, because
either (A) the plan is a new plan or (B) option 4(a) below is checked or the plan already offers a
pre-retirement distribution option at least as generous as 4(a).)
c. ( ) April 1 of the calendar year following the later of the calendar year in which the
participant attains age 70½ the Applicable Age (defned in section _____ of the plan
document) or the calendar year in which the participant retires, except that benefit
distributions to a 5-percent owner must commence by April 1 of the calendar year
following the calendar year in which the participant attains age 70½. the Applicable
Age.
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