Keane's Unclaimed Property Blog

CARES Act – Impact on Escheatment of Retirement Plans

The Coronavirus Aid, Relief, and Economic Security Act, or CARES Act, was signed into law on March 27, 2020.   Under Section 2203 of the Act, required minimum distributions (RMDs) from IRAs (including inherited IRAs) and certain other retirement plans are waived for 2020.

In addition to the waiver in 2020 of newly occurring RMDs, this includes a waiver of the initial RMD for IRA owners who reached age 70.5 and would have been required to take their RMD by April 1, 2020.  With the waiver, the new RMD date becomes April 1, 2021. 

Combined with the SECURE Act, which moved the age upon which RMDs must commence from 70.5 to 72 (if the owner had not reached age 70.5 before January 1, 2020), the effect for unclaimed property purposes is essentially a suspension in 2020 of the period after which these accounts will be presumed abandoned.

🔊 As a follow up, the content of the alert above only applies when a retirement account’s required minimum distribution (RMD) date is the trigger that starts the running of the dormancy period


Escheat Law, Legislative Alerts, Unclaimed Property Law


I'm looking for information on...