I'll preface this with I shouldn't have procrastinated...

My previous employer (I left several years ago) is changing their 401(k) provider from Company A to Company B and I never did anything with my plan when I left so it's still with Company A.

If I let it get moved to the new 401(k) provider (Company B) during the switch, is that considered a rollover?

I ask because I can easily leave it with Company A (they've been hounding me as I assume they want to keep my money), but I'm assuming that would be considered a rollover from my previous employers plan, which as I understand it, it means I can't move it again for another year. I know that I'll want to do something with it within a year.

1 Answer 1


No that is not a rollover. Many employees have experienced a change of management companies. Sometimes these switches are due to a merger, an acquisition, or just to save money.

It is understandable that the old employer would like to see you transfer your funds to either your new employer, or roll them over into a IRA/Roth IRA. So it is not unexpected that they will take this opportunity to nudge you.

The thing that congress was trying to prevent were serial rollovers of IRAs. These people would use the 60 day window to have in essence a loan. Some would do this multiple times a year; always making sure they replaced the money in time.

The IRA One-Rollover-Per-Year Rule

Beginning in 2015, you can make only one rollover from an IRA to another (or the same) IRA in any 12-month period, regardless of the number of IRAs you own (Announcement 2014-15 and Announcement 2014-32). The limit will apply by aggregating all of an individual’s IRAs, including SEP and SIMPLE IRAs as well as traditional and Roth IRAs, effectively treating them as one IRA for purposes of the limit.

* Trustee-to-trustee transfers between IRAs are not limited
* Rollovers from traditional to Roth IRAs ("conversions") are not limited

Direct transfers of IRA money are not limited

This change won’t affect your ability to transfer funds from one IRA trustee directly to another, because this type of transfer isn’t a rollover (Revenue Ruling 78-406, 1978-2 C.B. 157). The one-rollover-per-year rule of Internal Revenue Code Section 408(d)(3)(B) applies only to rollovers.

Note that the law doesn't mention 401K/403B or the federal TSP.

When the 401K changes management companies that is not a rollover.

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