529 Plan used for college application fees?

Was chatting with a friend yesterday who’s child applied to 24 colleges last month, and is waiting for her acceptances/decisions/financial aid etc. She told me that she just withdrew $2,000 from their 529 plan to pay off their charge card for these application fees that were paid to the schools in 2015.

I didn’t think that 529 plans could be used before the student enrolls in higher education. Her approach was that her child will be enrolled in the fall of 2016, so it is fine to take the withdrawal in 2016. Based on the schools her child is looking at, she is expecting to pay $25K per year or so for tuition, and she said her 529 plan has just under $100K in it. So she figured if she has to pay $12.5K in the fall, she will have withdrawn $14.5K in 2016, and she will be fine.

Something about this doesn’t feel right to me - perhaps since we didn’t do this ourselves last year or 4 years ago, I am feeling like we missed an opportunity.

Does anyone have any thoughts on this?

Your friend is wrong. College application fees are not a 529 Qualified Education Expense. To the extent that 529 distributions for the year exceed QEE, your friend will need to pay tax and an additional 10% penalty on the earnings portion of the distribution.

Saw my friend for lunch, and she brought this issue up as she is filing her taxes like many of us. She told me they paid $12.5K in late July, and another 12.5K on 12/30/16 for the spring semester. She took a total of distribution of $20K from the 529 during calendar year 2016 so her QEE’s (25K) exceeded the 20K distribution (2K in Jan, 12K in July, and 8K in December), so no tax penalty on the 529 distributions.

Since her costs were more, she paid the rest out of income/current assets. I thought it was a creative way to help her cash flow (which was tighter in January than it was at the end of the year), as I was unaware that 529 distribution dates did not have to match up with the QEE payments.

I told her I would have thought she’d have been better off paying more out of the 529 plan during CY 2016, as I have been told its better to use that up early so the student can qualify for more need based aid during the later years.

Sometimes the family doesn’t qualify for FA as a freshman with $80k in the 529 plan or as a senior with $10k left in the 529. It really depends on the income and other assets. Many people never qualify for need based FA.

Maybe it just worked better for their budgeting to split the 529 into 4 equal amounts for the 4 years.

Maybe they claimed the AOTC?

@twoinanddone - I think it was the cash flow / budgeting that worked them. My friend’s child attends an expensive school that has given him a lot of FA, but they still have to kick in a sizeable amount.

I was under the impression that most 4 year colleges will expect that families will use the 529 funds over all 4 years - are you saying that isn’t the case? If a family has $100K in a 529 plan before freshman year, and uses a quarter of it each year, shouldn’t they expect the same amount of aid each year?

But if they use up more than a quarter of it in the first year, then when they apply for the next year, I have been told they’d appear more needy (as 529 assets are treated differently in the need calculations, and are “assessed” at a higher rate than other assets) and could qualify for more financial aid (especially at a school that “meets” full need).

My S graduated last year from Columbia and D is at Stanford. We had very meager 529 plans, and we used them pretty much equally over 4 years for S. For D, we were advised that we should use what we had right away, so that D will qualify for more aid for her last 3 years - to offset the fact that we had one fewer family member in college.

A college financial planner told us that the biggest mistake people make in paying for college is failing to start saving early enough. But a second, very very common mistake people make, is that they fail to look at this as a 4 year series of problems - they only look at the current year. Even people who are smart enough to run the NPC’s, will not also run them under different combinations like what happens to FA next year when older sibling graduates.

Colleges FA advisors are really helpful when asked “what about” questions - they do not give personal financial advice, and they will tell you to consult with your own personal tax advisor or financial planner. They often can’t tell precisely how much next year’s tuition and board will increase. They will tell you how much aid you could expect next year, and that the formula is recalculated every year etc. But they understand how families are struggling to pay for the biggest expense in their child’s life, and they want to help.

So why not ask them what would have been the difference in your FA if you had $20 K in a 529 vs. having it in cash, or having invested in your 401K? Ask them what happens next year when you go from a family of 4 to a family of 3? Or a family of 6 drops to 3 when the triplets graduate? Ask if it makes a difference if your older child is still a dependent, or attending grad school? What happens if a parent changes jobs, and income goes up or down by $20K? Ask what happens if you get an inheritance during they time your child is in school. Whatever issue you reasonably think will affect your own family, chances are that the school has dealt with it, and they should be able to give an idea as to how it could impact your FA application. It doesn’t cost anything but a few minutes to re-run NPC’s.

For some of us, it can be maddening to think that we could have gotten better financial aid, or gotten a bigger tax credit, whatever, if we had done a few simple things differently. We can’t predict everything in the future, but there are usually things we can/should think about ahead of time that can impact our decisions.

My understanding is that 529 funds are simply counted as parent assets. They are not treated differently than other parent assets. So, to the extent you spend 529 funds earlier, you are lowering the parent assets. Since parent assets are assessed around 5% (depending on FAFSA vs CSS Profile), for every $1000 you spend, you appear to need $50 more aid. Of course, it’s up to the school whether they actually give you more aid.

I don’t think it’s the case that most 4 year colleges will expect that families will exhaust the 529 funds over all 4 years. This is not how FAFSA calculates the use of 529 funds, and I don’t think it’s how most Profile schools do, either.

For FAFSA purposes, 529 assets are not treated differently in the need calculations – they are assessed just the same as any other reportable parent asset. Schools that use Profile for dispensing institutional funds can treat 529 accounts any way they want, but I certainly would not make the blanket claim that “529 assets are treated differently in the need calculations, and are “assessed” at a higher rate than other assets.” Where are you getting this from?

^As far as the CSS Profile, there is no specific question about 529 funds. The CSS Profile does have a section where specific schools can ask additional questions and such a question about 529 funds could exist in that section.

Parent-owned (and possibly student-owned, depending on school policy) 529 account balances would be reported in Profile question PA-120. The worksheet for PA-120 does have a specific line for “section 529 college savings or pre-paid tuition plans.” However, completing the worksheet is not mandatory, and any 529 account balance reported on PA-120 could be lumped in with other amounts that make up the general category of “market value of parents’ investments.” Without a break down in the worksheet, the school will not know how much of this amount is stocks, bonds, mutual funds, CDs, non-retirement annuities, commodities, precious metals, 529 funds, etc.