RMD Tracking Automation: Don't Miss Another Distribution

November is when a manual RMD process shows its gaps. RMD-eligible clients haven't taken distributions. Some have died and the beneficiaries don't know what to do. Some are spread across multiple custodians and the firm doesn't have a clean view. The penalty for missing an RMD is significant (25% of the missed amount, reducible to 10% with timely correction under SECURE 2.0).

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 (under SECURE 2.0, age 73 for clients born 1951 through 1958 and age 75 for clients born 1960 or later), 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 worth it

Three reasons:

Penalty avoidance. The excise tax is 25% of the amount that should have come out and did not, reduced to 10% if the shortfall is corrected in time (IRC section 4974, as amended by SECURE 2.0). A missed $10,000 distribution means a $2,500 excise tax before any correction relief. Even with relief, the friction and client-relationship damage is significant.

Capacity recovery. Chasing RMDs by hand takes staff time that belongs to client work. Log those hours this year, and you will know what automation is worth to your firm next year.

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. 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

Some 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. The limit is indexed for inflation: $108,000 per person for 2025 and $111,000 for 2026 (IRS Notice 2025-67, IRB 2025-49).

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. It is a conversation worth opening well before year end.

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. Vendor tools can get this wrong, so verify yours against the current rules.

What drives the time and cost

• The number of custodians to integrate, and whether each offers an API or only scheduled reports
• How many clients hold IRAs away from your custodians
• How much inherited-IRA logic your book actually needs
• Whether outreach runs through your existing CRM or a new channel

Most of the build time goes to the custodian integrations and to pinning the calculation rules down correctly. Get a written scope and quote before work starts, and budget separately for recurring compute and support. For reference, Prometheus publishes its own starting prices: a defined build from $5,000 and a multi-system engagement from $25,000.

To measure payback, set the one-time cost against the staff hours you logged on RMD follow-up and against the penalty exposure on any shortfall the pipeline catches.

If you want to scope a deployment for your firm, that's a conversation worth having before November.