Oh WOW. Yes FIL (his IRA) died over 10 years ago. That IRA is now in MIL's name. I'm not sure exactly how it is titled. MIL passed in August. I think that the Annuities are treated the same since both were created well before the Secure Act. However the Annuity and the IRA are different things albeit tied together in a strange way. There seems to be separate distribution rules for annuities within IRAs that pre-existed before Secure.
https://www.investmentnews.com/secure-act-creates-wrinkle-annuities-inherited-iras-192873
So how do I determine if this is Is this really complicated or am I just overthinking it? I guess this may be just 1 more reason for not including annuities within IRAs. I will probably just have DW close out the annuities within the IRAs and move the Inherited IRAs to our primary custodian.
Step 1 is to read each of the annuity contracts and find out what is supposed to happen when the owner dies. Once you know that, you can figure out whether things are really complicated or not.
Aside from that, here's a good article on successor beneficiaries: https://www.kitces.com/blog/success...le-secure-act-eligible-designated-beneficary/
With respect to your FIL's account, your wife's case is "Scenario #2" in this article.
Subject to the same ‘exception’ for surviving spouses as discussed above, any Successor Beneficiary inheriting an IRA, 401(k), or other retirement account from an individual who died before the SECURE Act’s effective date will find themselves subject to the SECURE Act’s 10-Year Rule.
For your MIL's own accounts, your wife is a "Non-eligible Designated Beneficiary" who is subject to the SECURE Act's 10-Year Rule.