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distribution from in-plan roth rollover account


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The plan does not allow in-service withdrawals at any time. The plan does allow in-plan Roth rollovers. The plan also allows distribution from in-plan Roth rollover accounts at any time. The plan would like to change that so the in-service distribution options for the in-plan Roth rollover account are the same as the rest of the plan (withdrawals from rollover accounts are not permitted at any time).

Is the distribution from in-Plan Roth rollover accounts a protected benefit? Can it be completely eliminated so that the in-plan Roth distributions are the same as the in-service distributions?

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The plan does not allow in-service withdrawals at any time. The plan does allow in-plan Roth rollovers. The plan also allows distribution from in-plan Roth rollover accounts at any time.

Are you sure about the last sentence above? Our VS document has the post 2013 in-plan conversion language in an interim amendment and the base document addendum portion says that distribution restrictions applying to the source(s) being converted continue to apply after the conversion. Also, it's not possible to allow in-service of converted deferral or safe harbor accounts prior to age 59.5 after the conversion. Could the in-service distribution provision you are referring to be the one for regular rollover accounts?

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