"Trump Accounts are a new form of traditional individual retirement account (IRA) that the 2025 reconciliation law (P.L. 119-21) created for the benefit of children. Savers will be able to contribute to Trump Accounts starting on July 4, 2026.... Anyone can contribute to a child's Trump Account, although individual contributions during the growth period are not tax-deductible for either the contributor or the beneficiary. Employers can contribute up to $2,500 (adjusted for inflation after 2027) tax-free to the Trump Accounts of employees or their dependents (amount is per employee, per year)." MORE >>
"Legislation that would have laid the groundwork for a state-run retirement plan providing coverage for those whose private-sector employers do not offer a retirement plan had been coursing through both chambers of the Tennessee legislature. But not anymore -- that language has been replaced with wording that would instead authorize the state of Tennessee to serve as a non-bank custodian for Trump Account funds." MORE >>
"The proposed rules don’t address employer contribution programs, employer “matching” the Treasury’s contribution, employee salary deductions, investments or ERISA matching considerations ... What do employers need to know? IRS and Treasury are encouraging parents to set up Trump accounts for their children. Parents must actively elect to open an account. Accounts must be set up before an employer can make contributions or deposit salary deductions." MORE >>
"Under this designation, BNY will manage the initial accounts and help develop the new Trump Accounts app -- a secure, user-friendly platform that will enable families to easily access and manage their accounts. As part of this process, BNY has partnered with Robinhood, which will serve as brokerage and initial trustee for Trump Accounts. Together, these partners will support Treasury's goal of ensuring every eligible child can access a Trump Account quickly and easily." MORE >>
"The proposed regulations would apply to tax years beginning on or after January 1, 2026, with final rules expected in early 2027.... The IRS has expressly reserved further rules governing contribution administration, investments, distributions, reporting, and employer contribution programs. As a result, Trump accounts are authorized but not fully operational and stakeholders should expect additional regulatory detail before broader program implementation can proceed." MORE >>
"Employers interested in making contributions to Trump Accounts or facilitating employee contributions to Trump Accounts may wish to begin planning now to identify open questions as well as internal resources and assistance that may be needed from service providers, in particular if there is a desire to have a program in place under a cafeteria plan in time for open enrollment near the end of 2026." MORE >>
"It remains to be seen what level of 'buy-in' will occur from individuals and employers. The initial funding of new accounts under the Treasury's pilot program might encourage parents to establish a Trump Account for their children to at least seed the accounts with those contributions. Trump Accounts also might be used as a wealth-transfer vehicle if parents and grandparents make contributions on behalf of their children and grandchildren." MORE >>
"Trump accounts are set to launch in July ... However, many policy experts are already speculating on how they could be further integrated into the retirement system, such as using them to assist in account consolidation and to increase uptake of the Saver's Match." MORE >>
"The Treasury Department and IRS recently released additional guidance related to these accounts within two coordinated notices of proposed rulemaking that address the critical threshold questions of [1] how Trump accounts are opened generally, and [2] how the one-time $1,000 government 'pilot program' contribution is deposited into the accounts of eligible children born from 2025 through 2028." MORE >>
"Given the rules for setting up an Account and the annual contribution limitations, a child's family members and relatives should carefully coordinate their efforts to open Accounts, make contributions and elect the $1,000 pilot program contribution for the family's various eligible children. It may be helpful to submit comments on the need for guidance to mitigate excess contributions due to miscommunication among family members." MORE >>
"Building upon predecessor guidance in Notice 2025-68, the proposed rules provide clarity around account eligibility, who is authorized to establish a TA, and how the establishment process works -- information employers who plan to offer a Trump Account Contribution Program (TACP) will need to successfully draft eligibility guidelines and determine what to include in their benefit communications to employees." MORE >>
"While the [Notice 2025-68] and the Proposed Regulations provide important clarity on how Trump Accounts are opened ... several open questions still remain.... [1] Eligible investment; [2] Distributions during and after the Growth Period; [3] Reporting requirements for trustees and custodians ... [4] Nondiscrimination testing for Code Section 128 employer contribution programs; [5] Guidance exempting Trump Accounts from ERISA (similar to that of HSAs); [6] Coordination of salary reduction contributions with Code Section 125 rules." MORE >>
"[T]he IRS has received several comment letters from investment managers and their advocates calling for greater diversification in the permitted investments, including more international exposure.... Meanwhile, Annamaria Lusardi, a finance professor at Stanford University ... argues that keeping the accounts simple -- rather than introducing complex global investing options -- will lead to better outcomes for first-time investors." MORE >>
"[In proposed regs] the IRS explained that automatic enrollment will not work for Trump accounts, despite the urging of many commenters ... [T]here were two issues ... The first is that the administration of individual accounts is not the same as the defined contribution (DC) plans that have made wide use of auto-enrollment.... Secondly, the IRS said that it could not auto-enroll because it could violate tax privacy laws under Section 6103." MORE >>
"The proposed regulations on the $1,000 pilot program detail the requirements for making the election to receive this contribution from the Treasury Department.... Although much of the text deals with exactly how the IRS views the contribution -- as a 'deemed overpayment of tax' by the child and then a refund -- one provision seems to stand out. This $1,000 payment can be made to the child up to the year the child turns age 17.... [A second set of] proposed regulations define various terms; explain how to make an election to open the account; and clarify who can open an initial account, how to open the account, and how to designate the responsible party to manage the account." MORE >>
"The proposed regulations issued today provide rules on how the Secretary of the Treasury will make one-time $1,000 pilot program contributions to the Trump Accounts of eligible children for whom elections have been made. The proposed regulations provide guidance regarding the effects of making an election for an eligible child to receive a $1,000 contribution and define other qualifications." MORE >>
"This document contains proposed regulations relating to Trump accounts.
The proposed regulations provide guidance on making an election to open a Trump
account and reserve additional sections for further guidance on Trump accounts. The
proposed regulations would affect children eligible to have a Trump account, individuals
who would make elections with respect to those children, and trustees of Trump
accounts." MORE >>
34 pages. "This document contains proposed regulations relating to the Trump accounts contribution pilot program under which the Trump accounts of eligible children can receive $1,000 pilot program contributions. Eligible children must be U.S. citizens with valid Social Security numbers born in 2025 through 2028. The proposed regulations would provide guidance on making an election for the Trump account of an eligible child to receive a $1,000 pilot program contribution. The proposed regulations would affect eligible children and individuals who would make elections with respect to those children." MORE >>
"In response to IRS proposed regulations for Trump accounts, the investment management industry has pushed back against requiring Trump accounts to be invested in at least 90% U.S. equities." MORE >>
"A [recent poll] found that close to 16% of respondents plan to offer Trump Account funding options, whether that's through pre-tax employee contributions or direct employer contributions, or are actively considering doing so. Yet, over half said they do not expect to 'take any action' with Trump Accounts, and 30% report feeling undecided." MORE >>
"The promise of giving kids 'free money' surely piqued the interest of children and parents alike. Employers, however, are not all rushing to incorporate Accounts into the suite of benefits offered to employees.... [T]he vast majority are waiting on more guidance to determine how the Accounts will operate in conjunction with existing benefits offered to employees." MORE >>
"One of the requirements under Section 128 of the Code for a valid employer-provided Trump account contribution is that the employer adopt a 'separate written plan.' Although additional guidance may be needed before finalizing a separate written plan document, in light of commentary in the Notice concerning the anticipated requirements of a Trump account contribution program, Section 129 dependent care assistance program plan documents may provide a good starting point for plan sponsors that are considering offering employee pre-tax contributions to Trump accounts." MORE >>
13 pages. "For Trump accounts to be a success, they need to integrate seamlessly with the existing retirement system.... Treasury must support parents who want to use a private Trump account provider by making the rollover process easy.... Treasury should confirm that Trump accounts may charge account-based fees to support the administration and reporting of the account.... Treasury should confirm that Trump accounts may pay for investment advice and that this is not considered a distribution from the account." MORE >>
24 pages. "A competitive marketplace for account trustees and custodians is key to the long-term success of the Trump Account program ... Treasury should facilitate the availability of rollovers to preferred providers by issuing sample language and model forms for Trump Accounts ... Treasury should provide trustees and custodians the flexibility to develop reasonable approaches for monitoring compliance with the annual contribution limit and for returning excess contributions[.]" MORE >>
"[OBBBA] creates 'Trump Accounts' under new IRC Sec. 530A, which functionally act like a more restrictive [IRA]. Qualifying children born between January 1, 2025, and December 31, 2028, will qualify for a one-time, $1,000 deposit to an account. No income limitations apply. The accounts must be created by an authorized individual such as a legal guardian, parent, adult sibling or grandparent, which may have some families asking: Is it worth it to open one of these accounts?" MORE >>
