jlint3024, if the Required Beginning Date for RMDs is April 1, 2020 as seems to be implied by your question, your RMD is not late and no Form 5329 or explanation is required. If your RMD was required to have been completed by December 31, 2019, yes, you must file Form 5329 and request waiver of the penalty after you complete the late RMD.
