Do FAFSA applications require reporting 401k loans and Roth IRA withdrawals as income?
I'm filling out the 2025-2026 FAFSA for my daughter and I'm confused about what counts as income. Last year, I took out a $12,000 loan from my 401k to cover some emergency home repairs. I'm paying it back through payroll deductions. I also withdrew $5,500 from my Roth IRA that I've had for over 10 years. Do either of these need to be reported as income on the FAFSA? I don't want to mess up her financial aid by reporting incorrectly. The FAFSA instructions aren't clear on retirement accounts and I'm worried about getting flagged for verification if I do this wrong.
18 comments


Charlotte Jones
Great question! For FAFSA purposes: - 401k loans are NOT reported as income. Since you're borrowing your own money and repaying it, the Department of Education doesn't consider this as income for your SAI (Student Aid Index) calculation. - For Roth IRA withdrawals, it depends. If you withdrew only contributions (not earnings) from a Roth IRA that you've had for more than 5 years, those withdrawals are generally NOT reported as income on FAFSA. However, if you withdrew any earnings, those earnings may need to be reported. Remember that FAFSA now uses prior-prior year tax information, so they'll be looking at your 2023 tax return for the 2025-2026 application.
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Logan Greenburg
•Thank you so much! That's a relief about the 401k loan. For the Roth IRA, I believe it was all contributions since I've had the account for over 10 years and my contributions were more than what I withdrew. Do I need to provide any documentation proving this was just contributions, or does FAFSA just use what's on my tax return?
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Lucas Bey
i think 401k loans count as income bc you got money? my brother did this and his kids got less aid. IRA stuff definitely counts, my financial advisor told me never touch retirement if you have kids in college
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Harper Thompson
•This is incorrect information. 401k loans are not counted as income for FAFSA purposes because you're borrowing your own money and repaying it. It doesn't appear on your tax forms as income. For Roth IRAs, qualified distributions of contributions are tax-free and don't affect FAFSA. Your brother's situation likely involved other factors that reduced aid.
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Caleb Stark
Just went through this exact situation last year! The 401k loan is NOT counted as income on FAFSA. However, when I took money from my Roth IRA, I had to be careful. The financial aid office asked for additional documentation during verification to prove it was just contributions I withdrew (which aren't counted) and not earnings (which would count). Make sure you have statements showing your contribution history ready if they flag you for verification.
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Jade O'Malley
•omg the verification process is a NIGHTMARE. we got selected last year and it took 5 months to get everything sorted out!!
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Hunter Edmunds
I'm dealing with a similar situation with my retirement accounts. What I've learned is that the FAFSA primarily uses your tax return information. If your 401k loan and Roth IRA withdrawal didn't show up as taxable income on your tax return, then you generally don't report them on FAFSA. For Roth IRAs specifically, qualified distributions aren't taxable so they shouldn't impact your SAI calculation.
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Logan Greenburg
•That makes sense! Just checking - our 401k loan definitely doesn't show up on our tax return, and the Roth withdrawal didn't either since it was just contributions. So it sounds like neither one should affect our FAFSA? The instructions are so confusing compared to the old EFC system.
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Ella Lewis
Be SUPER careful with this! The financial aid office at my son's college claimed our 401k loan counted as "untaxed income" even though it wasn't on our tax return, and they reduced his aid package by almost $4,000!!! We had to fight for weeks to get it fixed. The rules say one thing but the individual schools can interpret differently. I spent HOURS trying to reach someone at Federal Student Aid to get clarification and kept getting disconnected or sitting on hold forever.
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Charlotte Jones
•You're right that individual financial aid offices sometimes make these kinds of errors in professional judgment. Did you eventually reach someone at FSA to get it resolved?
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Ella Lewis
•YES! But only after I found this service called Claimyr (claimyr.com) that got me through to an actual FSA agent without the endless hold times. They have a video demo showing how it works: https://youtu.be/TbC8dZQWYNQ. The agent confirmed 401k loans are NOT considered untaxed income for FAFSA, and I had them send that in writing to my son's financial aid office. Worth every penny because we got the aid reinstated!
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Harper Thompson
Let me clear up some confusion here with the official guidelines: 1. 401k loans: These are NOT reported as income on FAFSA because they are loans you're repaying, not income. They don't appear on your tax return as income either. 2. Roth IRA withdrawals: - Withdrawal of contributions: NOT counted as income for FAFSA - Withdrawal of earnings: Only counted if they appear as taxable income on your tax return The key thing to understand is that FAFSA is primarily looking at what's reported on your tax return. If something doesn't show up there as income, it generally won't affect your SAI calculation. One exception: some schools may ask for additional information on their institutional aid forms (like the CSS Profile) that goes beyond what FAFSA requires.
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Logan Greenburg
•Thank you for the clear explanation! Her school doesn't require the CSS Profile, just FAFSA, so it sounds like we're in the clear. This is so much less stressful now.
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Jade O'Malley
wait i'm confused...isn't there a question on FAFSA that specifically asks about untaxed income?? wouldn't a 401k loan count for that since you got money that wasn't taxed? the whole system is rigged anyway, they say middle class families get help but my family makes 95k and we got NOTHING for my brother's college 🙄
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Harper Thompson
•The "untaxed income" question on FAFSA is looking for specific types of income that weren't taxed (like untaxed portions of IRA distributions or tax-exempt interest), not loans. A 401k loan isn't income at all - it's your own money that you're temporarily accessing and paying back. That's why it doesn't count for FAFSA purposes. Regarding your aid situation, the new SAI formula for 2024-2025 and beyond is actually more generous to middle-income families than the old EFC formula was. Your brother might qualify for more aid under the new system.
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Logan Greenburg
Thanks for all the helpful responses! Just to confirm what I'm understanding: neither my 401k loan nor my Roth IRA withdrawal (since it was just contributions) need to be reported as income on the FAFSA since neither showed up as taxable income on my tax return. I'll keep documentation ready in case we get selected for verification, but it sounds like I've been worrying unnecessarily. This definitely helps me feel more confident about completing my daughter's FAFSA application correctly!
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Aisha Mahmood
That's exactly right! You've got a good understanding of the rules now. Since neither transaction appears as taxable income on your tax return, you don't need to report them on FAFSA. One small tip for peace of mind: when you submit your FAFSA, make a note in your records about these transactions and keep your documentation handy (401k loan agreement, Roth IRA statements showing contribution history). That way if you do get selected for verification, you'll have everything ready to go and can quickly resolve any questions. Good luck with your daughter's financial aid application! The new FAFSA system can definitely be confusing, but you're handling it correctly.
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Sean Doyle
•This is such helpful advice! I'm new to this whole FAFSA process and was feeling overwhelmed by all the different rules about what counts as income. Reading through this thread has been really educational. I'm curious though - do you know if there are any other common retirement account transactions that people often get confused about when filling out FAFSA? I want to make sure I'm not missing anything else that might trip me up.
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