By Sarah Brenner, JD
Director of Retirement Education
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In 2020 and 2021, when I was over 65 years old, I converted some of my IRA into a Roth IRA.  Does the five-year rule still apply to me, or can I now draw out all of the Roth IRA without any tax consequences? Also, I made the initial conversion in December of 2020, if the five-year rule does apply, do I need to wait until December 2025 to draw on it or can I draw on it anytime in 2025?




Hi Howard,

This is an area where we get many questions. There are two five-year rules that apply to Roth IRA distributions.

The first five-year rule applies to converted funds. If you are under 59 1/2, and you take a distribution of converted funds within five years of the conversion, a 10% penalty will apply. This five-year rule does not apply in your case because you are over age 65.

However, there is a second five-year rule that applies when there is a distribution of earnings, and that does apply to you. If your first Roth conversion or contribution was for 2020, you must wait until January 1, 2025 before you can access your earnings from your Roth IRA tax-free.


I know you can delay taking your first required minimum distribution (RMD) until April 1 of the year after you turn 73. If you convert your entire IRA into a Roth before that date but after you turn 73, do you still have to take your first RMD distribution or is no distribution required as the entire IRA is converted prior to April 1 of the following year?

Best regards,



Hi Tom,

If you convert in the year you reach age 73, you must take your RMD prior to the conversion. This is because you must take an RMD for that year, and the rules say that the RMD must be the first money distributed from the IRA. This is true even though the deadline for taking an RMD is April 1 of the following year.

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