Great article on the details and risks of 72t / SEPP withdrawals
- Christopher Bahnsen, MS, CLU

- Apr 24
- 1 min read
An excellent but not technically easy to digest article I recently read on 72t/SEPP withdrawals from Kitces.com:
Notice 2022‑6 quietly made 72(t) / SEPP plans more usable for early retirees by modernizing how “substantially equal periodic payments” are calculated. The IRS now allows a higher interest rate (the greater of 5% or 120% of the mid‑term rate) when you use the fixed methods, which can significantly increase the penalty‑free income a 72(t) plan can provide in those early years. The notice also updated the safe‑harbor methods and life‑expectancy tables, and clarified that you can make a one‑time switch from a fixed method to the RMD method without automatically “busting” the plan, giving planners a modest amount flexibility to adjust as circumstances change.
At the same time, 72(t) is still a strategy with a substantial amount of complexity and some risk. The calculations are somewhat technical and have individual trade-offs. The rules are rigid, and an error or later “modification” can trigger a retroactive 10% penalty on all prior distributions plus interest. Layer in the impact on taxes and long‑term retirement balances and this is not a straightfoward area.
If a 72(t) plan is on your radar, it’s a great area to slow down and work with a qualified, fee‑only advisor or tax professional who can model the tradeoffs and help you implement it correctly.

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