Thanks so much for you prompt replies and advice. We will certainly read the article and take that into consideration. THANKS AGAIN

It’s really up to you. Remember these contributions to the Roth are not separate from regular Roth contributions. So your older children may be making (or wanting to make) their own contributions.

I’m honestly a big fan of leaving the money in the 529 plan and letting it grow for the future. You already earmarked this money for education. You could potentially create an education dynasty for your future family here. You might find this interesting: multi-generational 529 plans.

ugh. I figured the IRS wouldn’t make it easy! We have the bulk of the money in the youngest’s account; less that $150 in the other two. We were hoping to move money around to split evenly and then convert to Roth. I guess it makes sense to just roll over the one account over 2+ years rather than waiting 5 years for the other two. (Make sense?). Do we bother even rolling over the other two? The tax implications shouldn’t be that much on the others, I would think.

Understood. So Fidelity isn’t misleading you – there is no specific clarification from the IRS at this point on your question. We’re waiting on exact guidance and language.

My opinion (this is my belief – not verified by the IRS yet), is that a rollover would count as a contribution and your 5 year waiting period starts from that date. The reason is that you’re effectively adding money to their plan (you are especially doing this from one beneficiary to another). The premise is that you’re supposed to use “left over” money and it should be left over for at least 5 years.

Did not change beneficiary.