Beginning balance to determine 72t distribution

L1: Beginning balance to determine 72t distribution
On Nov 1, 2018 I rolled my 401k to an IRA. I’m setting up a new SEPP plan. I am 54 years and 6 months old. I’d like to take my first distribution either this month (November 2018) or during January 2019. My question is what beginning account balance do I use for my 72t calculation. The balance on Nov 1, 2018 when I rolled to the IRA? Or an average balance throughout the year on the 401k account before it rolled to an IRA? Or the balance of the 401k on December 31 2017? Any assistance would be appreciated.
2018-11-20 04:27, By: Happy Camper, IP: [96.18.209.176]

L2: Beginning balance to determine 72t distribution
Hello Happy,
I had just about the same question a few months back. It seems the written law does not get into specifics. Everyone agreed that as long as you use a value in good faith you will be fine.
You could use the value from November 1, November 15, or any date that makes sense. If you wait until January to take the first distribution I would suggest your Dec 31, 2018 balance.
2018-11-20 05:20, By: RD99, IP: [187.254.2.144]

L2: Beginning balance to determine 72t distribution
If your company allowed you to take partial distributions after you retired, you could have waited until Jan 2019 to retire. Then you would not have been locked into a SEPP 72-T for 5 years, and would have had complete flexibility to take whatever amounts that you wanted to, and whenever you wanted to.
Also, did you check with your company about NUA valuation ?
If either of these alternatives were available to you, then you might not be a “Happy Camper”.
2018-11-20 06:22, By: dlzallestaxes, IP: [173.59.46.223]

L3: Beginning balance to determine 72t distribution
You can never use a balance from a different type of plan, therefore you must use your IRA balance after the rollover was done. You have a choice of dates to choose from since the rollover was just done. Normally, you want to use the highest balance but due to current market losses, the highest balance will likely be within a few days of the rollover arriving in the IRA. There is also a requirement that when you start your plan, the balance used for your calculation must be a “reasonable” representation of the current balance.
That means if the market rout continues and your balance dropped substantially (meaning more than 15%) by the time you start your plan, you should not be using that higher value since it is too much higher than the current value of your IRA when you take your first distribution. Unlikely it would drop that much, but that is still possible.
2018-11-20 18:12, By: Alan S, IP: [72.24.226.251]

L4: Beginning balance to determine 72t distribution
Thank you all so much for your responses. Considering the market I think I’ll wait for January 2019. Best to all.
2018-11-21 03:43, By: Happy Camper, IP: [96.18.209.176]