The new rules are optional for plans starting this year & mandatory for plans starting next year. Section 4:
I'd take this to mean that existing plans that started prior to 2022 are not affected, except that plans using the RMD method can switch to the new life expectancy tables. (This is the part I'd been waiting for.)The guidance in this notice replaces the guidance in Rev. Rul. 2002-62 and Notice 2004-15 for any series of payments commencing on or after January 1, 2023, and it may be used for a series of payments commencing in 2022. In the case of a series of payments commencing in a year prior to 2023 using the required minimum distribution method, if the payments in the series are calculated by substituting the Single Life Table, the Joint and Last Survivor Table, or the Uniform Lifetime Table described in section 3.02(a) of this notice for the corresponding table that was used under Rev. Rul. 2002-62, then the substitution will not be treated as a modification within the meaning of section 72(t)(4) or section 72(q)(3).
New plans using the annuitization & amortization methods can apparently use an interest rate of up to 5% if the 120% federal mid-term rate is less than 5%. Section 3.02(c):
The interest rate that may be used to apply the fixed amortization method or the fixed annuitization method is any interest rate that is not more than the greater of (i) 5% or (ii) 120% of the federal mid-term rate (determined in accordance with section 1274(d) for either of the two months immediately preceding the month in which the distribution begins).