529 to ROTH 15yr rule

Can anyone confirm that the 15yr rule for the 529 being in existence is similar to, say, a ROTH IRA 5yr rule? Meaning, a client opened the 529 over 15yrs ago, but just recently moved custodians. The 529 itself has been open for over 15yrs, but the newest account has only been open for a few months. Would this account still qualify for the 529 to ROTH option? Thank you!



This is yet another question among the many issues regarding these transfers that will have to be resolved by IRS Regs. I doubt that many prior 529 transfer dates to different plans have been tracked by the current custodian.  It will be a challenge to resolve all of these issues as well as the reporting requirements for both 529 plans and Roth custodians in time for such transfers to take place in just 8 months. 

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