Q. I reached age 70½ in 2011, therefore must make my initial required minimum distribution from my Thrift Savings Plan account before April 1. Which table should I use to determine my RMD? My spouse is my only beneficiary and is more than 10 years younger than me; so, it seemed to me that the appropriate table is the Joint and Last Survivor Table. However, two different TSP customer service representatives have informed me that I must use the Uniform Lifetime Table, and that only those who have established annuities within their accounts (which I have not done) are permitted to use the J&LS table if they meet its beneficiary and spouse’s age requirements. I have scoured 26 CFR 401(a)(9) thoroughly and can find nothing stating that, for a defined contribution plan, an annuity is required for use of the J&LS table. Do the TSP regulations include a requirement for an annuity and, if so, how does TSP justify exceeding the Code of Federal Regulations requirements?
A. What the rep meant to say was that if you want the TSP to automatically calculate and make monthly distributions based on your life expectancy, they will only use the Uniform Lifetime Table. If you want to use the Joint and Last Survivor Table, you’ll have to calculate the RMD amount each year yourself and request the required distributions using fixed monthly payments.
