RMD Tracking Automation: Don't Miss Another Distribution
Required Minimum Distribution tracking, calculation, and client outreach — automated end-to-end for advisory firms. Pre-empts the November panic.
A well-deployed AI tracking pipeline turns this from an annual fire drill into a calm, advisor-led January cadence.
What "RMD tracking automation" actually means
Three layers:
1. Identification
Every client who's hit RMD eligibility (currently age 73 under SECURE 2.0, transitioning to 75 by 2033), every inherited IRA owner subject to the 10-year rule, every spousal-rollover situation — surfaced before January 1.
The pipeline ingests custodial data and demographic data to identify every eligible account. Filters by account type (Traditional IRA, Inherited IRA, 401(k) where the client is no longer with the employer, etc.). Flags edge cases (still-working exemption for current employer 401(k), Roth IRAs not subject to lifetime RMDs).
2. Calculation
Required minimum amount calculated per account using the appropriate IRS Uniform Lifetime Table or Single Life Expectancy Table (for inherited IRAs). Aggregated across accounts where aggregation is permitted (IRAs aggregate; 401(k)s don't aggregate with IRAs or with other 401(k)s).
The calculation uses December 31 prior-year balance pulled directly from custodial records. Pipeline tracks any distributions already taken in the current year and reports remaining required.
3. Outreach
Personalized client communication generated for each client based on their preference (email, mail, phone scheduling). Communication explains the required amount, options (cash distribution, in-kind, qualified charitable distribution), and asks for the client's election.
The output is a coordinated outreach plan that runs from late January through early Q4, with escalation paths for non-responders.
Why automating this is high ROI
Three reasons:
Penalty avoidance. A missed RMD on a $200k Traditional IRA costs the client $50k under SECURE 2.0's reduced penalty (25% × $200k). Even with correction relief, the friction and client-relationship damage is significant.
Capacity recovery. Most firms spend 40-80 advisor-team hours in November chasing RMDs manually. Automation reclaims those hours for actual client work.
Service signal. Clients who get a January letter reminding them their RMD is identified and ready to schedule perceive their firm as proactive. Clients who get a November scramble call perceive the opposite.
The build
Five components:
Data extraction layer: pulls account-level positions and YTD distribution history from custodians (Schwab, Fidelity Institutional, Pershing, etc.) via API or scheduled report ingestion.
Calculation engine: applies the correct table, handles aggregation rules, accounts for already-taken distributions, generates per-account and total-required amounts.
Client preference layer: pulls communication preferences from CRM (Redtail, Wealthbox), advisor assignment, and any historical distribution patterns (some clients always do QCDs; some always take it as in-kind).
Communication generation: drafts personalized client outreach per their preferences. Includes their required amount, options, and a click-to-schedule for the call to confirm.
Tracking dashboard: advisor-facing view of every RMD-eligible client, what's been distributed, what's pending, what the deadline cascade looks like.
Compliance considerations
RMD calculation is a fiduciary-adjacent activity. A few rules:
- Calculation accuracy is the firm's responsibility. AI-calculated amounts should be verified against the custodian's own RMD-calculation tools where available. We treat the AI calc as the working number and the custodian calc as the supervisor check.
- Aggregation rules vary by account type. Most IRAs aggregate. 401(k)s don't aggregate with IRAs and don't aggregate with each other (each plan's RMD must come from that plan). The pipeline must encode these rules correctly.
- Client signature still required for non-discretionary distributions. AI generates the outreach; client elects and signs.
- Document the methodology. If a client questions the calculation later, the pipeline must produce a clean audit trail showing the prior-year balance used, the table applied, and the calculation.
QCD opportunity
A meaningful percentage of RMD-eligible clients are charitably inclined and don't realize they can use a Qualified Charitable Distribution (QCD) to satisfy the RMD while avoiding the income recognition. Under current rules (2024+ indexed), up to $108,000/year can be QCD'd from IRAs.
An AI pipeline can flag clients with both RMD obligations and historical charitable giving patterns (visible in CRM notes, tax documents shared during planning, or directly from client conversations) and surface the QCD opportunity to the advisor proactively. This is a high-impact, low-effort touch that compounds client retention.
What gets stuck
Two common failure modes:
Multi-custodian aggregation. Clients with IRAs at three custodians need aggregated RMD calculation. The pipeline must either ingest all custodian data or rely on client-disclosed held-away accounts (see our held-away monitoring guide). Without complete data, the calculation is wrong.
Beneficiary IRA timeline confusion. SECURE Act and SECURE 2.0 changed beneficiary IRA distribution rules significantly. The 10-year rule for non-spousal beneficiaries, the eligible designated beneficiary categories, the at-least-as-rapidly rule — each has its own logic. AI pipelines that don't encode these rules correctly will give wrong answers for inherited IRAs. We've seen vendor tools get this wrong; verify yours.
Deployment time and cost
For a firm with 200-500 RMD-eligible clients:
- Build time: 4-6 weeks (most of it integrating with the custodian data + getting the calculation rules pinned correctly)
- Annual cost: $1k-$3k/month for compute + retainer
- One-time deployment: $20k-$40k depending on scope
If you want to scope a deployment for your firm, that's a conversation we have weekly.
Frequently asked questions
What's the current RMD age?
Under SECURE 2.0 (effective 2023), RMD age is 73 for those who reach age 72 after 2022. It moves to 75 in 2033. Always verify against current IRS guidance.
How is the RMD penalty calculated under SECURE 2.0?
Missed RMDs incur a 25% excise tax on the amount not distributed (down from 50% pre-SECURE 2.0). Reduced to 10% if corrected within a 'correction window' (generally before IRS assessment). Both are significant; automation pays for itself avoiding one of these.
Can we aggregate IRA RMDs?
Yes for IRAs of the same type held by the same person. Traditional IRAs aggregate with other Traditional IRAs (and SEP/SIMPLE). Inherited IRAs do not aggregate with the beneficiary's own IRAs. 401(k)s do not aggregate with anything — each plan's RMD must come from that plan.
What's a Qualified Charitable Distribution and why does it matter for RMDs?
A QCD allows IRA owners 70½+ to send IRA money directly to a qualified charity. The amount counts toward the RMD requirement but is excluded from taxable income. 2024 limit is $105,000/year (indexed). Highly tax-efficient for charitable clients with RMDs.
Does this work with multi-custodian clients?
Yes if you have data feeds from all relevant custodians or held-away account visibility through client disclosure. Without complete account visibility, the RMD calculation will only cover the accounts you can see. Plan for held-away aggregation as part of the build.
Related guides
Need help implementing this?
//prometheus does onsite AI consulting and implementation in Milwaukee. We set it up, train your team, and make sure it works.
let's talk