Section 3. Required Beginning Date.

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 the

Applicable Age.

b. ( ) April 1 of the calendar year following the calendar year in which the participant

attains 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 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

122 | Defined Benefit Plan LRM Package 06/2026

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 specified 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), 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 the Applicable Age (defined 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 the Applicable Age.