Based on the Legislation, the 529 account designated beneficiary does not appear to be subject to the Roth IRA income limits; however, as of the date of this summary, the IRS has not provided guidance on the provisions of the Secure 2.0 Act of 2022 but is anticipated to do so in the future. Based on forthcoming IRS guidance, it may be necessary to change or modify some of the 529-to-Roth IRA transfer requirements. Please consult with a financial or tax professional regarding your specific circumstances prior to making an investment, including a 529-to-Roth IRA transfer.