NPVAdvisor : Hi, please don't shoot the messenger here, but it IS. Based on the contribution (rather than when the INITIAL contribution was made or account opened)
NPVAdvisor : See this, from IRS: ( note the language re: contribution, rather than account age)
NPVAdvisor : What Are Qualified Distributions?A qualified distribution is any payment or distribution from your Roth IRA that meets the following requirements.It is made after the 5-year period beginning with the first taxable year for which a contribution was made to a Roth IRA set up for your benefit, andThe payment or distribution is:Made on or after the date you reach age 59½,Made because you are disabled (defined earlier),Made to a beneficiary or to your estate after your death, orOne that meets the requirements listed under First home under Exceptions in chapter 1 (up to a $10,000 lifetime limit).
NPVAdvisor : Here's an excellent resource:
NPVAdvisor : The five-year rule is somewhat confusing. There are actually two five-year rules for Roth IRAs, one for tax-free distributions and one for penalty-free distributions. The five-year rule for tax-free distributions starts when the first Roth IRA was established. That Roth IRA can be used to satisfy any additional Roth IRAs established. In your case, this rule was satisfied about 2007, five years after your first Roth contribution.Converted funds in a Roth IRA have their own five-year rule, if the account owner is under age 59 ½. You are over age 59 ½ so this rule does not apply to you. For those under 59 ½ with the converted amount held for less than 5 years, the distribution is subject to the 10% early distribution penalty. EACH CONVERSION HAS ITS OWN FIVE-YEAR HOLDING PERIOD – if you are under age 59 ½.
NPVAdvisor : ... From http://www.financial-planning.com/blogs/ask-ed-slott-roth-ira-five-year-rules-2678841-1.html
NPVAdvisor : Hope this helpe
NPVAdvisor : Lane
NPVAdvisor : ... Let me know if you have questions