Federal: AFC Response to Trump Account Program

May 8, 2026
Internal Revenue Service
Attn: Trump Accounts Contribution Pilot Program
1111 Constitution Avenue NW
Washington, DC 20224

Re: Response to Request for Information on the Trump Accounts

Dear Mr. Sandhu,

On behalf of the American Fintech Council (AFC),  I submit this comment letter in response to the Internal Revenue Service’s (IRS) Notice of Proposed Rulemaking regarding Trump Accounts (Proposed Rulemaking).  AFC is the largest and most diverse trade association representing financial technology companies and innovative banks, with a membership that spans banks, non-bank lenders, payments companies, and financial technology providers serving millions of consumers across the United States. On behalf of more than 150 member companies and partners, AFC appreciates the opportunity to provide input on the development of a comprehensive, durable framework governing Trump Accounts.

AFC supports policies that expand access to savings, promote long-term asset formation, and are implemented through clear, administrable, and platform agnostic frameworks. In the context of Trump Accounts, achieving these objectives requires a regulatory architecture that is precise in its definitions, consistent across market participants, aligned with existing tax-advantaged savings regimes, and capable of operating within modern financial infrastructure without unnecessary friction or duplication.

The perspectives set forth below reflect AFC’s commitment to advancing responsible innovation and durable policy design in this realm. In particular, AFC emphasizes the importance of regulatory clarity, uniform standards, and coordinated oversight to ensure that Trump Accounts function as a scalable and sustainable savings vehicle equipped to engender sustained asset accumulation over time. .

I. AFC Supports a Clearly Defined Statutory and Regulatory Framework That Establishes Consistent Eligibility, Contribution, and Account Standards to Promote Uniformity and Program Integrity

A durable Trump Accounts framework requires clear, administrable, and enforceable definitions governing eligibility, account structure, and permissible activities. Ambiguity in these foundational elements would introduce compliance uncertainty, increase operational burden, and create inconsistent outcomes across providers and account beneficiaries.

The final rule should define with precision what constitutes an eligible individual and establish uniform standards for account opening, designation, and administration. Eligibility criteria should be applied consistently across all participating institutions, with explicit requirements regarding age verification, Social Security number validation, and the authority of individuals permitted to make elections. Standardization in this area is necessary to ensure equitable access and reduce interpretive variability across institutions.

The framework should also establish definitive rules governing contribution limits, including coordination among individual contributions, employer contributions, and any government-provided contributions. The program should require clear aggregation rules, timing requirements, and enforcement mechanisms to ensure compliance and prevent circumvention of statutory limits.

In addition, the IRS should expressly define the legal classification of Trump Accounts in relation to other tax-advantaged vehicles, including traditional Individual Retirement Accounts (IRAs), Roth IRAs, and section 529 plans. Clarifying how Trump Accounts interact with existing savings frameworks, including rollover eligibility and contribution coordination, is essential to avoiding duplicative or conflicting treatment.

II. AFC Supports a Comprehensive Tax and Compliance Framework That Ensures Clarity, Consistency, and Administrability Across the Account Lifecycle

Clarity in the fiscal and compliance architecture governing Trump Accounts would be instrumental in ensuring the enduring viability of the overall framework. Final regulations should provide explicit guidance regarding the treatment of contributions, earnings, and distributions during both the growth period and the post-growth period. Equally important is a governing regime that establishes clear treatment of contributions based on source, including individual, employer, and government funding, and specifies whether such amounts are characterized as pre-tax or after-tax. Corresponding guidance should likewise articulate definitive standards governing earnings accrual and taxation, as well as the treatment of distributions, including any penalties, qualified uses, and the transition to traditional IRA treatment following the growth period.

Alignment of reporting and administrative obligations with existing IRA compliance regimes would also be appropriate, including the use of established forms, data fields, and reporting infrastructure. Reliance on familiar compliance channels would reduce administrative burden while preserving appropriate oversight.

Just as critical is a clear delineation of the responsibilities borne by trustees, custodians, and associated service providers with respect to reporting, withholding, and recordkeeping obligations. Such a precise allocation of responsibilities is necessary to prevent compliance gaps, avoid duplicative functions, and promote consistent supervisory outcomes.

III. AFC Supports a Standardized Consumer Protection and Disclosure Framework That Ensures Transparency and Consistent Treatment Across Providers

A national Trump Accounts program should incorporate standardized consumer protections that apply uniformly across all providers. Clear and consistent disclosures regarding account features, contribution limits, investment options, fees, and withdrawal restrictions should form a central component of that framework. In this realm is the standardization of disclosures across institutions in a manner that remains accessible to consumers, including through digital channels. Consistency in disclosure requirements is necessary to ensure that account holders and families are able to make informed decisions regardless of the provider through which an account is administered.

Further support for consumer confidence should come from safeguards designed to prevent misuse, including clear limitations on distributions during the growth period and appropriate controls governing account access and administration. Properly calibrated protections of this nature would safeguard beneficiaries while remaining faithful to statutory intent. No less significant is the need for uniform treatment across participating institutions so that similarly situated consumers receive comparable protections irrespective of delivery channel or provider model. Such consistency would strengthen supervisory oversight, reduce opportunities for regulatory arbitrage, and reinforce trust in the broader program architecture.

IV. AFC Supports a Coordinated, Technology-Agnostic, and Interoperable Framework That Promotes Competition, Accountability, and Long-Term Stability

The Trump Accounts framework should be coordinated across relevant regulatory authorities to ensure consistent implementation and to avoid fragmentation. Alignment between the IRS, the Department of the Treasury, and other relevant regulators is essential to ensuring that program requirements are interpreted and applied uniformly.

Furthermore, the program should adopt a technology-agnostic approach that accommodates modern financial services delivery models, including platform-based service providers operating in conjunction with regulated custodians. The rule here should explicitly recognize these arrangements and establish clear governance and accountability standards. In regular fashion, many fintech platforms operate through established clearing firms and IRA custodians that provide custody, recordkeeping, and IRA administration, while the platform manages enrollment, disclosures, and the overall user experience. Within these arrangements, fintech companies operate as subcontractors that adhere to appropriate governance, accountability, and fiduciary standards. However, the Proposed Rulemaking does not clearly articulate how the IRS intends to treat nonbank trustees and entities that rely on such fintech service providers within this structure.

Accordingly, the Department of the Treasury and the IRS should clarify that a trustee or custodian of record may satisfy applicable fiduciary experience requirements through the appropriately governed use of subcontractors or other qualified service providers, including those responsible for custody, tax reporting, and IRA administration. The fiduciary experience requirement should remain sufficiently flexible to account for modern, outsourced custodial models that are widely used across the financial services ecosystem.

Adopting this approach would align the Trump Accounts framework with existing market practices for similarly situated tax-advantaged savings vehicles and expand the range of eligible participants without diminishing accountability or supervisory oversight. In tandem, framework should also define the roles and responsibilities of trustees, custodians, and service providers, including clear allocation of liability and supervisory expectations. Explicit role definition is necessary to ensure accountability and reduce ambiguity in program administration.

Additionally, the program should allow for interoperability and portability across providers through standardized transfer protocols and reasonable limitations on transfer-related fees. These features are necessary to preserve consumer choice and promote competition, but should operate within a stable and predictable regulatory structure.

Overall, as a permanent program architecture, the framework should prioritize stability, predictability, and uniformity. Iterative or experimental elements that were appropriate in the pilot context should not be central to the final rule. Instead, the program should establish clear, durable standards capable of consistent application over time.

* * *

AFC appreciates the opportunity to provide comments on the proposed Trump Accounts framework. A clear, consistent, and administrable regulatory structure will be essential to achieving the program’s objectives of expanding access to savings and promoting long-term financial security. AFC and its members stand ready to engage further with the IRS and the Department of the Treasury to support the development of a framework that advances these goals while preserving innovation, competition, and consumer protection.

Sincerely,

Ian P. Moloney
Chief Policy Officer
American Fintech Council

[1] American Fintech Council’s (AFC) membership spans banks, non-bank lenders, payments providers, EWA providers, loan servicers, credit bureaus, and personal financial management companies.
[2] Internal Revenue Service, “Trump Accounts,” Federal Register 91, no. 46 (March 9, 2026): 11194–11204, https://www.federalregister.gov/documents/2026/03/09/2026-04533/trump-accounts.

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