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February 19, 2009




Mixing of retirement plan assets that may be required to be maintained separately for  certain reasons. For instance, adding regular IRA contributions to a conduit IRA is commingling, and results in the account losing it’s ‘conduit’ status.

Commingling is also used to refer to combining IRA assets with qualified plan assets, combining retirement plan assets with non-retirement plan assets.

Referring Cite

IRC § 408(a)(5)

Additional Helpful Information

IRC § 408(a)(5)  provide that “The assets of the trust will not be commingled with other property except in a common trust fund or common investment fund.”


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Applicable RMD Age

Applicable RMD Age The first year for which an IRA owner or plan participant must begin to take RMDs from their tax-deferred retirement account. RMDs

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Definition The minimum amount that must be withdrawn from retirement accounts, including qualified plans, 403(b) accounts, 457(b) accounts or IRAs, each year.  For retirement account

Required beginning date (RBD)

Definition The date by which a retirement account owner must begin distributing required minimum distribution (RMD) amounts from a Traditional,  SEP or SIMPLE IRA, a

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IRA Rules