IRS Rolls Out Sample Rollover Forms and Proposed Procedures

The Treasury Department and the IRS have issued Notice 2026-49, delivering on a SECURE 2.0 mandate (Section 324) to standardize the process for direct rollovers into and out of qualified retirement plans. (The notice is not applicable to rollovers or transfers between IRAs.) A 2013 report from the Governmental Accountability Office indicated that the current process is notoriously inefficient and error prone.

Five-Step Process Contemplated

The notice includes a five-step sample process using four different forms, all of which are optional at this point. There is no safe harbor for using the forms and no mandatory adoption date.

• The participant submits a Rollover Request (Form 1) to Receiving Plan.
• Based on the Participant’s Rollover Request, the Receiving Plan forwards the Receiving Plan’s Request to Distributing Plan (Form 2), which includes a "rollover identification number" (RIN) to be used throughout the process and a list of acceptable transfer (payment) methods.
• The Distributing Plan completes the Distributing Plan’s Rollover Certification (Form 3) to be returned to the Receiving Plan. This certification verifies the accuracy of the Receiving Plan’s Request to Distributing Plan, provides additional account information, and identifies the preferred transfer method.
• The Receiving Plan completes the Receiving Plan’s Rollover Acceptance (Form 4), which is delivered to the Distributing Plan to confirm acceptance and the transfer method.
• The Distributing Plan transfers funds through the agreed-upon method.

Moving Away from Participant-Delivered Checks

The Treasury Department is weighing whether to repeal the rule that permits mailing of direct rollover checks to participants and instead to require direct rollovers to move only electronically or by check sent straight to the receiving plan. Both payment methods seek to reduce or eliminate the number of participant-handled checks. Although the notice is designed to modernize the rollover process, no decisions are final. The notice acknowledges that any mandate would come with a transition period to allow providers to implement changes to their systems to comply with any such guidance.

Comments Due October 23

Providers and industry stakeholders who want to influence future guidance on this rollover process have until October 23, 2026, to file comments.

Will This Notice Affect the Superior IRA & HSA Platform?

Superior IRA & HSA has reviewed the notice for potential platform enhancements and has determined that we will not implement changes at this time because the proposed process and forms are optional. We will continue to monitor future IRS guidance, and if platform changes become necessary, we will implement updates and notify our clients accordingly.