By Sarah Brenner, JD
IRA Analyst


I have a question about avoiding RMDs for a still-working 73 year-old in a 401k plan.  I realize most people my age are looking forward to retirement, but I love what I do and am delighted to continue to be able to work.

I am about to change employers and would like to request a “direct rollover” from my old employer (who I still work for as of this writing) to my new employer (once all of the i’s are dotted and the t’s are crossed).  There will be/should be no gap in employment once all of the employment paperwork is complete and I turn in my official notice. (Not sure if that fact makes a difference).  Is there a requirement that I take an RMD in the year I change employers in conjunction with the change?  I do not know if my “old” (existing) employer will do a “direct rollover” to the new employer, or for that matter, if the new employer will accept a “direct rollover,” but I would much rather delay RMD’s against this account as long as possible.  Forewarned is forearmed and I would appreciate your take on this.

Many thanks


Interesting question! It sounds like you are taking advantage of the “still working” exception to the required minimum distribution (RMD) rules. This allows you to delay RMDs from a plan as long as you are still working for the employer who offers the plan. Not all plans allow this. Unfortunately, if you change jobs this year, you will no longer be able to take advantage of this exception with your current employer. This would mean you would have an RMD for this year, the year of separation from service. You would need to take this RMD before any funds could be directly rolled over to another employer’s plan. That is the bad news. The good news is that if your new employer is willing to accept funds from your current plan and offers the still-working exception, you will not need to take any RMDs for future years until you retire or leave that job.


Hi Ed,

My husband died in January at 74 years of age.  I am 57 this year.  He had not taken his RMD for 2019.  We have a donation we wanted to make upon his death.  It is less than the RMD.  I am wondering if since it is his RMD that I am taking if I can make it as a QCD?  I cannot find information on if the QCD option is only available to us while he was living.  Any help is appreciated.

Thank you,



Hi Shelby,

Our condolences on the recent death of your husband.

Unfortunately, while beneficiaries can do QCDs to satisfy RMDs, this is limited to beneficiaries who are 70 ½ or older. At age 57, you would not qualify to do a QCD to satisfy the RMD for this year. This is true even though it is the year of death and would have been his RMD had he lived.