Who should a 401(k) rollover check be made out to?
Summary
To the firm that holds your new IRA, "for the benefit of" you. Each firm spells out its own version: Schwab wants "Charles Schwab & Co., Inc., FBO (Your Name)," Fidelity wants "Fidelity Management Trust Company (or FMTC), FBO [your name]," and Vanguard accepts "Vanguard FBO [your name as it appears on your Vanguard account]." A check written that way isn't subject to withholding even if it's mailed to your house, while a check made out to you has already lost 20% to withholding and starts a 60-day clock.
Why your name is on it but the check isn't yours
FBO means "for the benefit of." The payee is the custodian; your name after FBO tells the custodian whose IRA the money belongs in. That's why the IRS treats "a distribution sent to you in the form of a check payable to the receiving plan or IRA" as not subject to withholding. The envelope can come to you. The payee line is what counts.
What you do with it when it arrives is set by the custodian. Fidelity notes that a check payable to it "does not need to be endorsed," and Vanguard says, "If the check is made payable to Vanguard, don't endorse it." You send it on, or use mobile deposit where the custodian offers it.
The details that hold a check up
Vanguard's list of common delays starts with a name mismatch: a check "made payable to a name that doesn't match your Vanguard account registration." A middle initial on the IRA registration that the old plan's records leave out is enough to cause it, so the name the plan prints has to match the registration before the check is cut.
The account number is the other one. Schwab asks you to give your old employer the IRA account number "and ask them to include it on the check, to avoid potential hold time." Fidelity and Vanguard ask for the same.
If the check is payable to you
Then it's not a direct rollover anymore. The IRS says a distribution paid to you "is subject to mandatory withholding of 20%, even if you intend to roll it over later," and you have 60 days from receipt to redeposit. Vanguard's instructions for that case: "endorse it, make sure it includes your Vanguard account number, and mail it to us within 60 days." To roll over the full amount, you'd need to add the withheld 20% from other money. As an example, a $50,000 distribution arrives as a $40,000 check ($50,000 × 20% = $10,000 withheld); redepositing only the $40,000 leaves $10,000 treated as a taxable distribution, and the IRS adds a 10% additional tax on it before age 59½ unless an exception applies. In the IRS's own example the withheld amount is reported as taxes paid for that year, and the site's page on 60-day rollovers and withholding runs those numbers for any balance.
Sources
- https://www.fidelity.com/retirement-ira/401k-rollover-ira-steps
- https://investor.vanguard.com/investor-resources-education/education/401k-to-ira-rollover-rules
- https://investor.vanguard.com/401k-rollover
- https://www.schwab.com/ira/rollover-ira
- https://www.irs.gov/retirement-plans/plan-participant-employee/rollovers-of-retirement-plan-and-ira-distributions
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