Trump Accounts (REG-117270-25)

The Utah Credit Union Association supports the proposed Trump accounts and the goal of encouraging early savings for children and families. They advocate for regulations that allow credit unions to serve as trustees, simplify the election process, and ensure efficient account portability and clear guidance on operational requirements.

The California and Nevada Credit Union Leagues support the creation of Trump accounts and the proposed rulemaking to implement them. They argue that credit unions are well-positioned to serve as trustees and request specific clarifications to ensure operational feasibility, such as recognizing credit union capital structures and allowing for streamlined rollover procedures.

The American Fintech Council (AFC) supports the development of the Trump Accounts but advocates for a clear, durable, and technology-agnostic regulatory framework. They emphasize the need for standardized eligibility, tax compliance, consumer protections, and interoperability to ensure the program is scalable and consistent across the financial services industry.

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 CFP Board supports the proposed "Trump Accounts" and expresses a willingness to serve as an advocate and education partner for the program. They request specific regulatory guidance on investment options, fees, contribution rules, and post-growth period distributions to help financial professionals effectively advise their clients.

The Securities Industry Financial Markets Association (SIFMA) supports the creation of Trump accounts as a tool for building long-term savings and wealth for children. They advocate for specific modifications to non-bank trustee requirements, clarification on account elections, and the streamlining of transfers to promote portability and operational efficiency.

The American Institute of CPAs (AICPA) supports the proposed regulations regarding Trump accounts but requests further clarification on specific definitions. They specifically advocate for a clearer definition of "available" regarding authorized individuals and recommend that the legal guardian or fiduciary be designated as the default responsible party to avoid familial disputes.

The commenter expresses support for the vision of the Trump Accounts program but identifies four specific regulatory and structural concerns that must be addressed before the program's launch. They are calling for clearer investment rules, the imposition of a fiduciary duty, an independent review of corporate conflicts, and increased financial transparency.

The Retirement Reform Group (RRG), an informal group of employee benefits lawyers, supports the proposed regulations for "Trump accounts" (section 530A IRAs) but argues that the IRS must provide additional protections and simplified guidance. They emphasize the need for clear "safe harbor" rules, financial education for inexperienced owners, and updates to the broader section 408 IRA framework to prevent mismanagement and fraud.