I understand that the 529 account has to be open for at least 15 years to be able to qualify to do a rollover to a Roth account for the beneficiary of the 529 account.  My question is, does it have to be with the same carrier for 15 years, or is it 15 years total?  For example, let’s say a client originally had a 529 account with American Funds for the beneficiary, but later transferred the account to Tomorrow’s Scholar.  Does the time at American Funds count towards the 15 years?