# Notice 2020-6: Relief for Reporting Required Minimum Distributions for IRAs for 2020

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URL: https://www.frixlaw.com/law-library/statutes/IRS_NOTICE_2020_6

## Section

- **Citation:** Notice 2020-6
- **Heading:** Relief for Reporting Required Minimum Distributions for IRAs for 2020
- **Jurisdiction:** Federal
- **Kind:** IRS notices
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** Internal Revenue Bulletin / IRB 2020 / Notice / Notice 2020-6

## Text

Relief for Reporting Required Minimum Distributions for IRAs for 2020
Notice 2020-6
PURPOSE

This notice provides guidance to financial institutions on reporting required
minimum distributions for 2020 after the amendment of § 401(a)(9) of the Internal
Revenue Code by the Further Consolidated Appropriations Act, 2020, P. L. 116-94 (the
Act).
BACKGROUND

The Act was enacted on December 20, 2019. Division O of the Act, titled
“Setting Every Community Up for Retirement Enhancement Act of 2019” (SECURE
Act), included a number of retirement savings provisions. Section 114 of the SECURE
Act amended § 401(a)(9) to change the required beginning date applicable to § 401(a)
plans and other eligible retirement plans described in § 402(c)(8), including individual
retirement accounts and annuities (IRAs). The new required beginning date for an IRA
owner is April 1 of the calendar year following the calendar year in which the individual
attains age 72, rather than April 1 of the calendar year following the calendar year in
which the individual attains age 70½.

This amendment to § 401(a)(9) is effective for distributions required to be made
after December 31, 2019, with respect to individuals who will attain age 70½ after that
date. As a result of this change, IRA owners who will attain age 70½ in 2020 will not
have a required beginning date of April 1, 2021. This means that these IRA owners

2

(who, prior to enactment of the SECURE Act, would have been required to take
minimum distributions from their IRAs for 2020) will have no required minimum
distribution (RMD) for 2020.
IRA REPORTING AND RELIEF

If an IRA owner has an RMD due for 2020, the financial institution that is the
trustee, custodian, or issuer maintaining the IRA must file a 2019 Form 5498 (IRA
Contribution Information) by June 1, 2020, and indicate by a check in Box 11 that an
RMD is required for 2020
stributions from their IRAs for 2020) will have no required minimum
distribution (RMD) for 2020.
IRA REPORTING AND RELIEF

If an IRA owner has an RMD due for 2020, the financial institution that is the
trustee, custodian, or issuer maintaining the IRA must file a 2019 Form 5498 (IRA
Contribution Information) by June 1, 2020, and indicate by a check in Box 11 that an
RMD is required for 2020. The financial institution may also choose to provide further
information in Box 12a (RMD Date) and Box 12b (RMD Amount). Additionally, under
Notice 2002-27, 2002-1 C.B. 814, if an IRA owner has an RMD due for 2020, the
financial institution must furnish an RMD statement to the IRA owner by January 31,
2020, that informs the IRA owner of the date by which the RMD must be distributed, and
either provides the amount of the RMD or offers to calculate that amount upon request.

The RMD statement required under Notice 2002–27 should not be sent to IRA
owners who will attain age 70½ in 2020. However, in recognition of the short amount of
time after the enactment of the SECURE Act that financial institutions have had to
change their systems for furnishing the RMD statement, relief is being provided. Under
this relief, if a financial institution provides an RMD statement to an IRA owner who will
attain age 70½ in 2020 (including by providing a Form 5498), then the Internal Revenue
Service (IRS) will not consider such a statement to have been provided incorrectly, but
only if the IRA owner is notified by the financial institution no later than April 15, 2020,
that no RMD is required for 2020.

3

For IRA owners who will attain age 70½ in 2020, the 2019 Form 5498 should not
include a check in Box 11 or entries in Box 12a or 12b.
OTHER MATTERS

The SECURE Act did not change the required beginning date for IRA owners
who attained age 70½ prior to January 1, 2020
RA owner is notified by the financial institution no later than April 15, 2020,
that no RMD is required for 2020.

3

For IRA owners who will attain age 70½ in 2020, the 2019 Form 5498 should not
include a check in Box 11 or entries in Box 12a or 12b.
OTHER MATTERS

The SECURE Act did not change the required beginning date for IRA owners
who attained age 70½ prior to January 1, 2020. In order to reduce misunderstanding
among IRA owners, the IRS encourages all financial institutions, in communicating
these RMD changes, to remind IRA owners who attained age 70½ in 2019, and have
not yet taken their 2019 RMDs, that they are still required to take those distributions by
April 1, 2020.

The Department of the Treasury and the IRS are considering what additional
guidance should be provided with respect to the SECURE Act, including guidance for
plan administrators, payors, and distributees if a distribution to a plan participant or IRA
owner who will attain age 70½ in 2020 was treated as an RMD.
DRAFTING INFORMATION

The principal author of this notice is Brandon Ford of the Office of the Associate
Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).
For further information regarding this notice, contact Brandon Ford at (202) 317-4148
(not a toll-free number).

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/IRS_NOTICE_2020_6. Check the current official text before relying on it. Not legal advice.
