The IRS recently released Notice 2020-06 which provides relief for reporting required minimum distributions (RMD) for IRAs for 2020 in recognition of the short amount of time that financial institutions had to update their systems after the enactment of the SECURE Act on December 20, 2019, which updated the age at which RMDs are required to begin from 70½ to 72. Financial institutions are required to send an RMD Notice to individuals who are required to take RMDs for that tax year by January 31st of that year. Based on the SECURE Act, individuals who turned 70 ½ in 2020 are not required to take an RMD in 2020; however, some financial institutions may have already sent these individuals their RMD notices or could not make changes to their notices to reflect these recent law changes. Notice 2020-06 provides that if a RMD notice was provided to an individual who turns 70 ½ in 2020, who under the SECURE Act would no longer need to take an RMD in 2020, the IRS will not consider such statement to be incorrect, provided that the financial institution notifies the IRA owner no later than April 15, 2020 that no RMD is due for 2020.
The IRS is considering what additional guidance should be provided with respect to the SECURE Act, including guidance to IRA administrators if an individual already took an RMD for 2020 but is not required to.