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Valuation and custody. If it is a direct rollover, valuation is not as sensitive as a practical matter. If the assets are publicly traded, neither valuation nor custody should be an issue, but check with the proposed IRA provider before lighting the fuse.

Retired, pop in here once and a while. Sorry to hear the gripes, having done software support for years on Pentabs (1992 - 1997). Worked my 'butt off' to learn the system and provide the best support I could, because it made a difference to me. Switched jobs when Pentabs closed down, did some training when a member of the Southern User Group, used to give away a number of Crystal reports I created. Have fortunately 'forgotten' much of the pension tuff, so no more grief of ADP test deadlines and the like. Now spending much of the time at church. Today is an especially glorious day for me. New tabernacle will be unveiled today, from funds I donated, quite a story with that, God gets what He wants when He wants.

I believe what you are suggesting is described as an ACAT transfer from one brokerage account to a new one, without liquidating any of the securities.

Your description is unconventional, so a bit confusing. A distribution event is necessary, but I presumed that.

At the time, idea of “cascading rollovers” had emerged. If you created several IRAs, you could serially roll over an amount from one to another, thereby almost effectively withdrawing the amount for some time (greater than the 60-day single rollover period) without paying taxes. It was like a juggler keeping one or more balls (the amount) in the air at all times. It is unlikely that an individual would be able to unilaterally line up multiple qualified plans to perform the same stunt.

Am I right in thinking IRC § 408(d)(3)(B)’s once-in-the-one-year-period rule applies for IRA-to-IRA rollovers, but does not constrain the frequency of rollover contributions into a § 401(a) plan? And am I right in thinking IRC § 402(c) does not impose such a once-a-year constraint for a rollover contribution into a § 401(a) plan?

I think there's confusion here between the statutory correction period of one year to avoid the excise tax (that has expired) and the 2-year (now 3-year) SCP correction period, which actually would not apply here anyway since it is certainly an insiginificant amount. But you are under EPCRS because went past the 1 year.

If the plan is ERISA-governed, an order does not fail to be a DRO or a QDRO (as ERISA § 206(d)(3) defines those terms) because of when the court made the order. (An order might fail to be a QDRO based on how what the order would provide relates to facts and circumstances that might have changed since the court made the order.) If the plan is a governmental plan, a church plan (that did not elect to be ERISA-governed), or otherwise not ERISA-governed, read the plan’s governing documents. Some plans of those kinds set detailed conditions for an order the plan recognizes, and those conditions might be stricter than ERISA § 206(d)(3) and Internal Revenue Code § 414(p).