I have a client whose company started a SIMPLE IRA plan for its employees using form 5304 (non-designated financial institution). The client wants me to manage his plan. My custodian recently changed and the new custodian has their own “prototype” SIMPLE IRA plan document in place. In addition, they are requiring either the company open up an account to create a “SIMPLE Master” account through which contributions to this one participant are funneled or a check mailed with a “transmittal form” that includes how much of the check is the employee’s contribution and how much is the employer match. Never mind the fact the custodian is now acting as a recordkeeper for these types of plans, the employer is not necessarily willing to be forced to open another account at another financial institution.

My question…. Can my client open a SIMPLE IRA at his bank, have the employer make the deposits there and then transfer the funds from bank SIMPLE IRA to brokerage firm SIMPLE IRA? Would this get into the one rollover per year issue if the funds are transferred rather than rolled over? What is the distinction there (I am pretty sure I know but want to make sure I am not overthinking or misinterpreting).

Thanks in advance!
Alan M