72T SEPP plan and Fidelity 401k

Looking to activate a SEPP plan in 2023 to distribute 30kish a year for 9 years (50 years old in 2023). Using the fixed amortization method that would require a sum of about 500k in the SEPP universe allocated to the plan. The first distribution of the full annual amount would be in November 23 and then the same annual amount would be distributed annually starting in Jan 24 (so there would be a temporary large infusion in the next few months which is convenient)

Considering 2 options. A Fidelity 401k w a former employer with about that amount OR rollover about half the 401k to an existing traditional IRA at Vanguard where there is also a sepira with 250k and creating a SEPP universe consisting of the vanguard traditional IRA and the sep IRA totally 500k.

The conventional wisdom I have read so far is to avoid trying to set up a SEPP directly against a 401k. Some concerns over lack of control I think compared to your own IRA accounts. Is this valid conventional wisdom or would the rollover be pointless? I think fidelity would allow SEPP distributions from the 401k and I don’t think any institution codes the distributions any differently. Fidelity did seem to insist on tax withholding at at least 20% which wasn’t convenient but not a deal breaker. Thoughts on these options or any flaws in how I’m describing the plan?



  • I would definitely avoid adopting a SEPP from a 401k plan. As you said there is too much lack of control, particularly if the plan has failed some testing requirement in the past and has to correct it with a contribution to the account. And there can be withholding rules interpretation issues as a 72t plan is not an eligible rollover distribution.
  • A recently on going SEP account can also present  excess (ND contributions) correction issues, but if the SEP IRA has been dormant for 3 years or so, it would be preferable to use the IRA/SEP universe for the 72t plan and perhaps transfer enough of the SEP IRA into the TIRA if this is an on going SEP IRA and have only the TIRA as the source account for the 72t.
  • Again, I would avoid the 401k plan for sourcing these distributions. 


The sep IRA has had no contributions in 5 years and I control it completely. I’m assuming that in the future if I wanted to make sepira contributions I could just create a totally different sepira account



Yes, you could. You might want to directly transfer the current SEP or at least the balance needed into the TIRA and have a simple one account 72t plan. 



Appreciate the feedback. Combining the sep IRA and tira hadn’t occurred to me for some reason. It does make it all cleaner. Thanks again 



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