Group Life & AnnuitiesQuestion 314 of 716

Which statement about required minimum distributions (RMDs) and qualified longevity annuity contracts (QLACs) is correct in 2026?

a.QLACs are prohibited inside qualified plans and inside IRAs alike: IRC §401(a)(9)(F) permits a deferred income annuity to be held only in a non-qualified account, so a participant who wants longevity protection must first take a fully taxable distribution and buy the annuity with after-tax dollars, and any annuity bought directly with plan assets is treated as a deemed distribution of the entire account balance and is reported by the administrator on a Form 1099-R
b.RMDs continue to begin at age 70½ exactly as they did under pre-SECURE law, because neither the SECURE Act of 2019 nor SECURE 2.0 disturbed the required beginning date for IRAs or employer plans; those statutes reached only the payout period allowed to beneficiaries after the owner's death, so an owner who reaches 70½ must still take a first distribution by April 1 of the following year or owe the shortfall excise tax
c.The QLAC dollar limit is unlimited: a participant may commit an entire IRA or plan balance to a qualified longevity annuity contract, and the amount excluded from the RMD calculation is bounded only by the requirement that annuity payments begin no later than age 85, because SECURE 2.0 repealed the QLAC purchase limit outright rather than replacing the old percentage cap with an indexed dollar ceiling, so no purchase limit survives
d.Under SECURE Act 2.0, the RMD beginning age has been increased to 73 (and rises to 75 in 2033 for those born in 1960 or later); separately, a QLAC under IRC §401(a)(9)(F) allows a participant to use up to a SECURE 2.0-increased dollar limit (generally $200,000 in 2024, inflation-indexed thereafter) of IRA / qualified plan assets to purchase a deferred income annuity that starts payments by age 85, with that QLAC value EXCLUDED from RMD calculations until annuitization

Explanation

The SECURE Act of 2019 raised the RMD age from 70½ to 72; the SECURE 2.0 Act of 2022 further raised it to age 73 effective in 2023, and it rises again to 75 in 2033 for those born in 1960 or later (IRC §401(a)(9)(C)). A QUALIFIED LONGEVITY ANNUITY CONTRACT (QLAC) under IRC §401(a)(9)(F) is a deferred income annuity purchased inside an IRA or qualified plan that begins payments no later than age 85. SECURE 2.0 increased the per-person QLAC purchase limit (eliminating the prior 25% of account value cap and raising the dollar cap to $200,000 in 2024, indexed thereafter), and the amount used to buy a QLAC is EXCLUDED from RMD calculations until annuitization begins — which is exactly the response combining the age-73 beginning date with the $200,000 indexed QLAC limit and payments starting by age 85. The response keeping the required beginning date at 70½ reflects pre-SECURE law. The response saying a QLAC may be held only in a non-qualified account is wrong; QLACs are expressly authorized inside IRAs and qualified plans. The response calling the QLAC limit unlimited is wrong; there is a statutory dollar limit.

Law Reference: SECURE Act 2.0 (2022); IRC §401(a)(9) (RMDs); IRC §401(a)(9)(F) (QLAC)

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