Trump Accounts (REG-117270-25)

The Annie E. Casey Foundation supports the Fostering the Future Accounts as a transformative tool for youth in foster care but recommends specific regulatory refinements to maximize their impact. They advocate for a 30-day enrollment standard, leveraging state treasury infrastructure, increasing contribution caps, expanding funding sources, and protecting means-tested benefit eligibility through age 26.

America’s Credit Unions, an advocacy organization representing credit unions, supports the proposed rule for Trump accounts but seeks specific operational clarifications. They argue for rules that ensure credit unions can act as trustees, including guidance on investment structures, fee caps, and simplified rollover procedures to ensure the statutory choice for families is practical.

America’s Credit Unions, an advocacy organization representing credit unions, supports the proposed rule for Trump accounts but seeks specific operational clarifications. They argue for rules that ensure credit unions can act as trustees, including guidance on investment structures, fee caps, and simplified rollover procedures to ensure the statutory choice for families is practical.

The California Child Savings Account (CSA) Coalition supports the proposed regulations for the 530A program but advocates for specific improvements to maximize inclusivity and simplify the enrollment process. They recommend exempting 530A assets from means-tested benefit tests, clarifying their impact on student financial aid, and authorizing state entities or community partners to assist with account opening for vulnerable children.

The Financial Technology Association (FTA) supports the proposed regulations for Trump Accounts but advocates for a platform-neutral ecosystem that prioritizes digital accessibility and competition. They recommend allowing direct account origination by private providers, standardizing technical infrastructure like ACATS and APIs, and modernizing trustee standards to accommodate digital-first business models.

The Pennsylvania Treasurer's office expresses strong support for the Trump Accounts and proposes a model where state agencies serve as qualified non-bank trustees. They argue that state administration leverages existing infrastructure to provide cost-effective, universal coverage and efficient long-term account stewardship for children.

The Louisiana Department of Children and Family Services (DCFS) supports the proposed "Trump Accounts" but argues that the current framework will systematically exclude foster children who lack available family members to open accounts. They recommend authorizing state agencies to act as "authorized individuals of last resort" to ensure these children can access the federal benefit and its associated growth period.

The Office of the Comptroller of Maryland, in collaboration with the Greater Washington Community Foundation and the CASH Campaign of Maryland, supports the creation of "Trump accounts" but recommends specific improvements to the proposed regulations. They advocate for incorporating features from "baby bonds" programs, such as auto-enrollment at birth, protections for children in foster care, tax-exempt status for means-tested programs, and the use of pooled trust structures to maximize returns.

The commenter is a nonprofit leader and consultant with experience working with the IRS who supports the creation of "Trump Accounts" but proposes specific improvements to the regulations. They recommend streamlining the enrollment process at birth, aligning eligibility standards, ensuring access for children in foster care, and improving fraud prevention and community outreach.