In the absence of IRS guidance, it is unclear whether a 529 beneficiary change will result in a reset of the 15-year account holding period required by the Legislation. We anticipate forthcoming IRS guidance may provide clarity on this and other related 529-to-Roth IRA transfer questions and will update our materials when more information is available. Please consult with a financial or tax professional regarding your specific circumstances prior to making an investment, including a 529-to-Roth IRA transfer.