In-plan Roth conversion.

[Guest Thornton]

Under the Roth in-plan conversion guidelines set forth in Notice 2013-74 (all money types), must the available converstion assets br 100% vested? If seems to make sense, but I can't find anything specific. If the answer is no, can the plan amendment require 100% vesting? Thanks

[masteff]

Unless you're trying to make a semantic about, say, 80% vested vs 100% vested, then yes, only vested amounts are allowed.

Notice 2013-74 Q&A-1 http://www.irs.gov/pub/irs-drop/n-13-74.pdf

Notice 2010-84 Q&A-2 http://www.irs.gov/pub/irs-drop/n-10-84.pdf