Roth IRA Subaccounts

Is it permissible to have a Roth IRA account with, say Schwab or Fidelity, but to farm out chunks of the money among several different brokers at other investment houses, to get access to different investments, while still staying nominally with the “home” custodian or trustee?

Presume the “home” custodian/trustee permits this and that funds are moved by direct custodian to custodian or TTEE to TTEE transfers. Also presume that the “home” Roth IRA account was a direct rollover from a 401(k) plan and that considerable after-tax assets are involved.

My understanding is that the farming out process will not create reportable events or otherwise leave a paper trail that is of any consequence with the IRS or, I presume, with the SEC to the extent involved.

I have received positive feedback on this question (e.g., yes it can be done) at another benefits message board and am seeking second or third opinions.



A mutual fund supermarket such as that offered by Schwab, Fidelity and many other discount brokers is acceptable but the IRA custodian remains Schwab. Under this arrangement, your transaction can only be done through Schwab and not directly with any of these other fund companies.

You can also set up as any IRAs are you wish by direct transfer or permitted rollovers, and each of these IRA custodians would provide you with an account number and IRA agreement.

If one of the above structures does not cover your depiction of “farming out” parts of your IRA, please clarify further the process you have in mind.

Whether your IRA was an employer plan rollover or contains after tax contributions is immaterial to the above. If you rolled over after tax contributions from an employer plan, you must file Form 8606 to report the amount. All IRA contributions or distributions leave a paper trail with the IRS except direct transfers from one IRA account custodian to another.



Thanks for commenting. I think what is desired is a bit more complicated that you are thinking. I would prefer to discuss via personal message, if that is ok w/you.



Sorry, but I limit correspondence to the public forum.

Attached is pasted from the tax code defining an IRA. The definition of “bank” is also listed in Sec 408(n), and contains some specific limitations.

Would be happy to continue exploring this here if you wish to clarify the process further including what if any transactions could be done without the knowledge of the “home” custodian.

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a) Individual retirement account
For purposes of this section, the term “individual retirement account” means a trust created or organized in the United States for the exclusive benefit of an individual or his beneficiaries, but only if the written governing instrument creating the trust meets the following requirements:
(1) Except in the case of a rollover contribution described in subsection (d)(3) in1 section 402(c), 403(a)(4), 403(b)(8), or 457(e)(16)2 no contribution will be accepted unless it is in cash, and contributions will not be accepted for the taxable year on behalf of any individual in excess of the amount in effect for such taxable year under section 219(b)(1)(A).
(2) The trustee is a bank (as defined in subsection (n)) or such other person who demonstrates to the satisfaction of the Secretary that the manner in which such other person will administer the trust will be consistent with the requirements of this section.
(3) No part of the trust funds will be invested in life insurance contracts.
(4) The interest of an individual in the balance in his account is nonforfeitable.
(5) The assets of the trust will not be commingled with other property except in a common trust fund or common investment fund.
(6) Under regulations prescribed by the Secretary, rules similar to the rules of section 401(a)(9) and the incidental death benefit requirements of section 401(a) shall apply to the distribution of the entire interest of an individual for whose benefit the trust is maintained
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Thanks. I will examine the regulations under the Sections cited, for more detail.



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