529 → Roth IRAWhat SECURE 2.0 actually allows, year by year
$35,000 lifetime cap
Per beneficiary, under current law — and it is not inflation-indexed. The sheet's "Post Graduation IRA" column assumed the entire leftover balance becomes an IRA; only this much can.
Annual limit = Roth limit
Each year's transfer counts against the regular Roth IRA contribution limit ($7,000 in 2024-25, IRS-indexed in $500 steps), reduced by any IRA contributions she makes herself.
15-year account rule
The 529 must be open 15+ years. Opened 2024 → eligible 2039. Changing beneficiary may restart this clock (IRS guidance pending).
5-year seasoning
Contributions (plus their earnings) from the last 5 years can't move. The model holds back recent contributions automatically.
Earned income required
The beneficiary needs wages ≥ the transfer that year. A working graduate clears this easily; a gap year doesn't.
Leftover entering rollover
$0
529 after graduation
Ever reaches the Roth
$0
cap $35,000 (not indexed)
Roth IRA at 68
$0
growing at 6.5%/yr
Stranded in 529 at 68
$0
education-only money — grandkids, or taxed + 10% exit
Drawn to brokerage at 68
$9,841,070
non-qualified exit · $0 lost to tax + 10% penalty
Planning lever: if the projection strands six figures in the 529, the fix is upstream —
trim contributions in the 2030s, or redirect the excess to a taxable brokerage / her own Roth once she has
income. The app's editor lets you test lower monthly contributions against each school path.