5 year rule on Roth conversions

An IRA expert out there that Ed knows and respects just said something on his radio broadcast tonight that is quite different than what my custodian, Fidelity, has said so I am hoping to find out who is right. I am well under 59.5 and have done several Roth conversions over the last few years including a substantial one this year. All of the conversions were done after the Roth receiving the conversions was over 5 years old. Fidelity has told me that each converted amount starts its own 5 year clock (starting Jan 1 of the year of the conversion so usually never a full 5 years) before the converted amount can be withdrawn tax and penalty free and that if the gains on the converted amount were to be withdrawan at any time, even after this same 5 year period, they would be taxed and have a 10% penalty for being pre 59.5. The expert said tonight that there is no clock (5 years or otherwise) on the converted amount so it could be withdrawan tax and penalty free the day after the conversion. The gains on the conversion would be treated as described by Fidelity. On the converted amounts specifically, who is right?



Fidelity is correct.

There are two totally different 5 year holding periods that affect Roth IRAs:
1) 5 years from the year of your first Roth contribution of any type. This requirement along with reaching 59.5 results in all your Roth IRAs becoming qualified, ie all distributions are tax and penalty free including earnings.
2) 5 year holding period for each Roth conversion. This one only affects the early withdrawal penalty for distributing the particular conversion. This holding period also ends upon reaching 59.5, ie once you reach 59.5 all your conversions can be distributed tax and penalty free.

The “expert” statement is totally incorrect. There is a 5 year holding period for each conversion up to age 59.5. But there are other exceptions that can waive this penalty as well, such as disability, first home purchase up to 10,000, certain medical and higher education costs etc. Perhaps this expert was referring to one of these specialized exceptions??



So without any of the noted exceptions, Fidelity has provided the correct information on the treatment of the conveted dollars with regards to their withdrawability?



Yes.



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