I know transferring funds from a 529 to a Roth IRA doesn’t begin until next year, but a question I have is say a client has two children, and has satisfied the 15 year required start date for each, and hasn’t put new funds into either account for more than 5 years. Only one child used all of their 529 savings for college, and the client wants to put the excess 529 savings into Roth IRAs for each child. If funds are first transferred from sibling to sibling, are these funds counted as new money (requiring a new 5 year waiting period)?