Roth in plan conversion

[Santo Gold]

I have a client with a 401(k) plan who is interested in making an in-plan Roth conversion. Just was hoping to confirm some issues involved with that:

(1) The plan has to be amended to allow for Roth contributions

(2) The participant has not yet made Roth contributions but can still have an in-plan conversion

(3) Any existing account balances attributable to 401(k), QMAC, QNEC, or Safe harbor contributions cannot be converted until at least age 59-1/2 and must be eligible rollover assets.

(4) Any amounts other than the above can be converted, but only if they are otherwise eligible for distribution (including in-service withdrawals) and are eligible rollover assets.

(5) Any amounts that are converted to Roth must remain in the plan for at least 5 years; otherwise, the earnings will be subject to taxation.

I also had a related question:

(A) Does the answer for #5 change depending on whether the distribution is a rollover or a lump sum cash distribution?

Thanks for any replies

[K2retire]

It was my understanding that the new law eliminates the need for in-service distribution or rollover eligibility. In other words, any money could be eligible for conversion at any age.