401(k) Rollover into A Roth IRA

[DTH]

When a Roth IRA accepts a rollover of non-Roth money from a 401(k) plan is there any special recordkeeping requirements (e.g., special source to house the non-Roth 401(k) plan rollover)?

Are there any special rules for the non-exclusion period? It is my understanding if designated Roth 401(k) contributions are directly rolled over to a Roth IRA that has not met the 5-year non-exclusion period, the non-exclusion periods is redetermined.

Example 1:

Roth IRA opened in 2003 (end of 5-year period is 12/31/2007)

Roth 401(k) rolled over to Roth IRA in 2008.

Roth IRA owner is age 59-1/2 or older, can take a qualified distribution anytime

Example 2:

Roth IRA opened in 2006 (end of 5-year period is 12/31/2010

Roth 401(k) rolled over in 2008 (end of 5-year period is 12/31/2012)

Roth IRA owner is age 59-1/2 or older, can take a qualified distribution beginning in 2013

Are my examples correct? Do these same rules apply to the rollover of non-Roth 401(k) money? Thanks!

[ERISAnut]

No,

Your second example is not correct. 2010 remains the date.

The initial date for the Roth IRA never changes.

The new 5 year period measurment ONLY pertains to a situation where there would have been a 10% early withdrawal penalty, but it was exempted because of a rollover to a Roth IRA. If the participant is actually 59 1/2, as outlined in your example, then there isn't a new 5 year period.