Multiple Roth rollovers - from other plans TO a new plan

[Belgarath]

Question - is it REQUIRED that a separate account be established for EACH external rollover from another plan? Ignoring possible practical reasons for the moment, I don't find that this is a requirement - a separate account/accounting is required, but I don't see why multiple rollovers can't be deposited to that 1 account. The 5-year clock will be based upon the first deferral date among the various accounts rolled in.

Assuming it isn't a REQUIREMENT, there may be good, practical reasons to establish separate accounts. Thoughts on that, based either upon theory or practical experience?

Thanks.

[masteff]

You appear to have read Reg 1.402A-1 Q&A's 4, 5, and 9. I'd say Q&A-9 is the closest to affirming that any and all rollovers can be put into the same bucket. I'd even go so far as to say both rollover and non-rollover designated Roth monies could be put in a single bucket if your plan didn't distinguish between them (e.g., same vs different distribution rules for rollovers, possible issues in determining hardship eligible money).

Since you correctly identified that per 1.402A-1 Q&A-4(b) the 5-year clock is based upon the earliest of all designated Roth monies rolled in (or those in the receiving plan if it predates the rollovers), I see no reason to keep each rollover separate. More specifically, we never tracked rollovers separately prior to this and I see nothing unique about them being designated Roth rollovers that would necessitate such now. EGTRRA did add the ability to rollover aftertax money, so off the top of my head you'd potentially have 3 rollover buckets: regular, aftertax, roth.

I too would love to hear if anyone has pratical experience that suggests otherwise?