Playbook · family · 529 / Roth / FAFSA

Fund school without raiding retirement

Free primer: 529 vs brokerage. Calculator: 529 vs taxable. Paid steps assume you already know tax-free growth has a string, and you want a file — not another “open a 529” slogan. There is no scholarship for your retirement. There are loans, jobs, and schools at many price points for theirs.

Do this in order

  1. Write a net-price number, not a sticker. Years until the first tuition bill. One realistic school from the College Scorecard / net-price calculator, not the highest private sticker in a brochure. Room and board if they will live on campus. That is the ceiling the 529 is allowed to chase. A 529 sized to “Harvard forever” is how people underfund the 401(k). Revisit the number when the kid is in 8th grade; do not wait for a financial-aid night.
  2. Retirement match and a cash sleeve before any 529 debit. Employer match is still the highest risk-free return at work — see never skip the match. Then a 3-month HYSA of essential bills, not of “feel-good.” If the 529 contribution would be a credit card, you wanted the paycheck sequence, not a 529. Do not cash a 401(k) for tuition. That is ordinary income, usually a 10% extra tax before 59½, and a prior-prior-year FAFSA income bomb.
  3. Split the leftover into three labeled piles. (A) money that is truly for school → 529. (B) money that might be school, a gap year, a house, or a car → taxable brokerage. (C) retirement that can double as a backup → Roth IRA contributions, not earnings. Pile B is how you keep optionality. Do not put rent, the emergency fund, or “maybe a down payment” in a 529 because a blog called it tax-free.
  4. Open or keep a parent-owned 529. Do not gift the account to the student. On the 2026–27 FAFSA, a parent-owned 529 is a parent asset. Parent assets raise the Student Aid Index at most 5.64%. A $50,000 parent 529 is at most about $2,820 of SAI. The same $50,000 in a student UTMA / student-owned account is assessed at 20% → $10,000 of SAI. Custodial 529s that started as UTMA still count as student assets. Title the account in a parent’s name. The kid is the beneficiary, not the owner.
  5. Pick the plan for the state deduction minus the fee, not the logo. Some states deduct (or credit) contributions only to the in-state 529. If yours does, run that deduction against the in-state expense ratio. If the extra 0.30% fee eats the deduction in a few years, or the state offers no break, a cheap out-of-state direct-sold plan is the classroom default. Age-based glide paths are fine if you will not tinker. Confirm the plan actually pays qualified K-12 / apprenticeship / loan / Roth-rollover distributions before you need one.
  6. Gifts and superfunding are Form 709 problems, not Venmo problems. 2026 annual gift-tax exclusion is $19,000 per donor per beneficiary (Rev. Proc. 2025-32 / IR-2025-103). A married couple can do $38,000. IRC §529(c)(2)(B) lets one donor elect to treat up to five years of exclusion as made now — $95,000, or $190,000 with gift-splitting — but only on a filed Form 709. A $95,000 dump without the election is a $76,000 taxable gift in year one. Direct tuition paid to the school (not room and board) is a separate unlimited gift-tax exclusion. Grandparents who want control and the 529 wrapper still use the 529; grandparents who only want this year’s bill can write the registrar.
  7. Grandparent 529: the FAFSA lag is dead. Stop following 2019 blogs. Through 2023–24, a grandparent 529 distribution showed up as student untaxed income on the next FAFSA and could cost ~50% of the distribution in aid. FAFSA Simplification (2024–25 onward, still true for 2026–27) stopped asking. Grandparent-owned 529 assets are not reported. Those distributions are not student income. The old “wait until after the last FAFSA” lag is stale for federal aid. CSS Profile and some state grants can still ask. The remaining reason to keep the 529 in a parent’s name is control and a clean SAI, not a timing trick. If Grandma already owns it, you do not have to retitle it for FAFSA anymore.
  8. Roth-for-education is a backup sleeve, not a 529 replacement. Roth IRA contributions (basis) come out tax-free and penalty-free at any age. Earnings taken for qualified higher-education expenses skip the 10% extra tax and are still ordinary income (Pub. 590-B). That is a worse tax result than a 529 qualified distribution. Use pile A first. Use pile B next (long-term gains, and the student’s 0% long-term bracket if their taxable income is actually there). Raiding Roth basis last. Do not skip the Roth annual cap ($7,500 under 50 in 2026, Notice 2025-67) to overfill a 529 you might not use.
  9. Know the 2026 qualified list before you swipe the 529 debit card. College: tuition, required fees, books, supplies, equipment, and room and board if at least half-time (Pub. 970). K–12: $20,000 per beneficiary in 2026, up from $10,000, and an expanded expense list (P.L. 119-21 / OBBBA §70413, distributions after Dec. 31, 2025). Student loans: $10,000 lifetime per borrower (SECURE Act §302). Apprenticeships and, after July 4, 2025, certain postsecondary credentialing expenses. Non-qualified earnings: ordinary income plus 10%. Scholarship / death / disability: 10% waived, earnings still taxable. Do not claim the American Opportunity Credit on the same dollars the 529 already made tax-free.
  10. Draw in the college years in this order, same calendar year as the bill. 529 to the bursar or to reimburse a qualified receipt dated this year. Then taxable lots. Then Roth basis. Grandparent cash that is a direct tuition payment to the school can sit next to the 529, gift-tax free. Do not take a 401(k) loan “just for freshman year.” Do not dump the 529 into a checking account in May for a bill that was paid last December — the match to a qualified expense is a year-of rule, not a vibe. Keep 1098-T, 1099-Q, and the receipt folder together.
  11. Leftover 529: change the beneficiary before you invent a Roth. A family-member beneficiary change (sibling, parent, cousin — Pub. 970 list) keeps the tax-free wrapper. Then the SECURE 2.0 valve: trustee-to-trustee 529 → the beneficiary’s Roth IRA, $35,000 lifetime, 15-year account age, last five years of contributions and their earnings ineligible, this year’s Roth cap ($7,500 in 2026, reduced by any regular IRA the beneficiary already funded), and earned income at least the rollover. No MAGI phase-out on the rollover slice. $10,000 of leftover can also pay that beneficiary’s (or a sibling’s) student loans. Do not overfund a newborn 529 “because of the $35k Roth.” The clock is 15 years and the cap is small.
  12. Hard-stop list: cashing a 401(k) for tuition, titling the 529 in the student’s name for “their money,” putting house-down-payment cash in a 529, following a 2019 grandparent-lag blog, skipping the match to max the 529, superfunding without Form 709, double-dipping AOTC and 529 on the same tuition, treating the 2026 K–12 $20,000 cap as room-and-board at college, raiding Roth earnings first, and assuming CSS Profile is as blind as the FAFSA. If the emergency fund is thin, you wanted the HYSA, not a 529 auto-debit.

One-page decision

Match + cash sleeve first. Parent-owned 529 for money that is truly tuition and required costs. Taxable for maybe-school. Roth contributions as the last-resort education sleeve. 2026 gift $19,000 / superfund $95,000 only with Form 709. Grandparent FAFSA lag is closed; CSS Profile is not. Draw 529 → taxable → Roth basis. Leftover: new beneficiary, then $35k Roth rollover, then $10k loans. Nobody is required to prepay a private sticker.

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