SEPP setup at a CU

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L1: SEPP setup at a CUI’d like to setup a fixed amortization SEPP at a CU in Feb 2010 that will run for 6.5 years. I’ll be opening a direct rollover traditional IRA with the funds going initially into an IRA share account that has the following account number: xxxxxx.80.01. The annual SEPP distribution will be calculated using the 80.01 balance. I will then setup an initial CD ladder that will provide the required liquidity for the first 3 years. After 3 years I’ll setup a new ladder. The CDs have different sub-account numbers: xxxxxx.81.01 (CD 1), xxxxxx.82.01 (CD 2), etc. So over the lifetime of the SEPP, funds will periodically be transfered between the 80.01 and the CD sub-accounts.
How should I define the SEPP universe under this arrangement? It’s a single IRA that is composed of multiple sub-accounts that change over time. Seems like the only option is to define it using the xxxxxx common account number. Is this how the IRS will see it? If I define it at the sub-account level, then it will change over time. So I don’t see how that could work.2009-11-11 03:30, By: kepler, IP: []

L2: SEPP setup at a CU>>It’s a single IRA that is composed of multiple sub-accountsIf it is one IRA account then that is the SEPP universe. No further definition required.2009-11-11 13:24, By: Gfw, IP: [::1]