In-Plan Roth Conversion of Employer SH Match

I'm finding vague references to this and looking for guidance.  In-plan Roth conversions are allowed in the plan, but I've never had a participant ask me if they can convert their pre-tax Safe Harbor Match to Roth.  Anyone have any insight on this?  Thanks in advance!

I'm not aware of any restrictions beyond what the Plan may or may not allow on sources eligible for conversion. It may be that you need to set up a special source in the Plan something like "In Plan SH Match ROTH Conversion" so you can properly track any in-service distribution restrictions of the original source money.

In order to discuss a conversion, one would have to have a plan provision which would hold Roth Employer contributions. Sec. 604 of SECURE 2.0 permits an optional treatment of Employer Matching or NonElective as Roth contribution. Although this provision has a 2022 effective date, it will have to be written into the plan document and it is optional.  I think the person asking the question is just a little ahead of the game.  None of us have amendments for these Employer Roth provisions yet and the IRS may provide further guidance.  So compliments for thinking ahead, but:  1. The plan would have to provide for this (It will not currently have an Employer Roth "bucket") ; 2. We don't have language for such an amendment today; and, finally, it is optional and the decision concerning adding it to the plan would be the plan sponsor's.

Perhaps I misunderstood the question but my assumption was the plan allows in Roth conversion, the participant has existing SH matching funds, and would like to know if he can convert those to roth. It's possible he has only ROTH 401(k) and Pre-tax SH Match and would simply like all ROTH, but that's simply a guess on my part.

I didn't contemplate this in the context of Secure 2.0 ROTH Employer contributions for which we have scant or no guidance at this point.