Risks of a Mistitled Inherited IRA?

There is plenty of great advice on here about how to properly title an inherited IRA — many thanks. My Q is: What are the risks/consequences if that titling is somewhat incorrect?

Longer version: My mother passed away a few years ago and left me a Roth IRA, which I kept at her old brokerage. I have been diligent about RMDs and other legal formalities, but would now like to do a trustee-to-trustee transfer of the Inherited IRA to my current brokerage.

Unfortunately, my current brokerage does not seem to be titling their inherited IRAs correctly. They are titling them as “[Client Name] of the Roth IRA of [Deceased Name], Brokerage LLC.” For example: ‘John Smith of the Roth IRA of Sarah Smith, Brokerage LLC.’

This is sort of close, but still seems plainly out of compliance with what Ed Slott recommends, which in turn derives from IRS Notice 2007-7, which requires a clear specification of beneficiary and decedent:

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A-13. The IRA must be established in a manner that identifies it as an IRA with respect to a deceased individual and also identifies the deceased individual and the beneficiary, for example, “Tom Smith as beneficiary of John Smith.”
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Not being a tax lawyer or CPA, I don’t know what risks are created if I just accept the new brokerage titling scheme and complete the transfer. Is their titling scheme “close enough,” or could it create real headaches? Is the IRS going to blow up my IRA when they see the 1099-R and claim I’ve lost the stretch rights?

The brokerage basically told me they’re aware of the issue, but won’t be able to fix it anytime soon.

And unfortunately, I really need to consolidate things at that particular brokerage, so finding a different brokerage is not viable. Thanks for any thoughts!



This brokerage surely could have done better than this titling format, but if there were any issues they would have had to fix it long before now, so you should be OK.  I guess everyone is assuming that the second name is that of the deceased owner.  I assume your 1099R forms are being coded T of Q in Box 7?

I appreciate the thoughts. I actually haven’t moved any accounts over yet — still trying to get comfortable with this. But I will have to pay extra-special attention to the coding I guess.I have an inherited regular IRA at Vanguard, and they code Box 7 as ‘Q’ currently. I also have an inherited Roth IRA at American Century, and they code Box 7 as ‘4’ (“Death”). 

You mixed up the two. The inherited Roth is coded Q, and the inherited TIRA is coded 4. The other thought I had is whether this custodian with the odd titling format might also handle other transactions inefficiently.

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