After tax and Roth check incoming; custodian did not offer direct rollover

A client’s recently deceased husband had a large amount of pre-tax $$ in one of his former employer’s 401(k)s, which is being directly rolled over. He has a smaller amount in after-tax and Roth $ in the 401(k). The custodian is not offering a direct rollover option for the latter; she expects to receive it as a personal check.

Can we deposit this with the new custodian for deposit to the widow’s Roth, assuming an immediate turnaround? If so, what particulars should we keep in mind?



  • A custodian must offer a direct rollover, but does not have to offer two.
  • However, if they do not over two they must offer a distribution of the second one.
  • Taxable distributions are subject to mandatory 20% withhold. That is why the pre-tax should be done as a direct rollover and the after-tax as a distribution.
  • A 60-day rollover of the after-tax distribution can be made to a Roth IRA.
  • It is up to the Roth IRA custodian whether they will accept a deposit of a third party check. They may or may not require depositing the check in a personal account and a new check or ACH transfer performed.

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