Ask Bob: Is It Possible to Put a Pre-CARES Act 2020 RMD Back into a Retirement Account?

Under the CARES Act, all 2020 required minimum distributions (RMDs) have been waived. But what if you took your RMD before the law went into effect?
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I took my 2020 required minimum distribution (RMD) on Jan. 2, 2020. Is there any way I can put part of it back into my IRA even though it is obviously over the 60-day limit? Is there any extension for this very unusual year?


The short answer is that it doesn’t look like you can put the money back into your retirement account because it came out before Feb. 1, says Natalie Briaud Pine, CFP, lead advisor and managing partner with BRIAUD financial advisors.

But, keep your eye on the IRS guidance that comes out regularly because that could change.

“The long answer is the 60-day rule still applies to all distributions in 2020,” she says, adding that in the IRS Notice 2020-23, they extended all deadlines that initially would have occurred between April 1 and July 14.

“The 60-day deadline for a distribution occurring on Feb. 1 would land on April 1, within this window. As such, according to the IRS, the deadline to put funds back into a retirement plan, distributed after Feb. 1, is before July 15,” Pine explains. Note that you are still only allowed one 60-day rollover every 365 days, so if you did one in the last 365 days, you cannot do another one.

In general, the IRS may waive the 60-day rollover requirement in certain situations if you missed the deadline because of circumstances beyond your control.

Read The Retirement Dictionary.

Got Questions? Get Answers.

Got questions about Social Security, Medicare, retirement, investments, or money in general? Get answers. Email Kim McSheridan assisted with this report.