<p>Yes, you can make a transfer from a UGMA to a UGMA/529 at any point prior to filing FAFSA. However, depending on the laws of your state, the UGMA might already be in the process of being converted to a non-custodial account in your daughter’s name (some states do this at 18, while in others it’s 21). Your brokerage firm will be able to help you with all of this.</p>