Trump Accounts: What’s Still to Come?

More than six months after President Donald Trump introduced new investment accounts for minors as part of the One Big Beautiful Bill Act, the Department of the Treasury has yet to publish final details on how those accounts will operate once their pilot program launches on July 5, 2026.

Trump Accounts, to be opened for children younger than age 18 and treated as traditional individual retirement accounts under Section 408 of the Internal Revenue Code, will have special “growth period” rules lasting until the year the child turns 18.

During the growth period, account funds can only be invested in certain low-cost, index-tracking investments, and account holders cannot make withdrawals except in limited cases such as rollovers or the death of the beneficiary. After that, the account converts to a regular IRA, with usual tax rules applying to withdrawals and early-distribution penalties.

Elizabeth Dold, a managing partner in Groom Law, says that “if you know the IRA rules, [you’re] 90% there.”

Kendra Isaacson, a principal in consulting firm Mindset, says she is “thrilled” and excited for what she considers a hands-on way to build financial literacy in the country. But she emphasizes that there is still ground to cover before the accounts debut.

“First, we have to get the nuts and bolts down, which is what I think you’re going to see January through July,” says Isaacson. “It’s critically important to get it right and have a successful start to the program because I think they can do so much good in the future.”

Recent Progress

Once launched, the pilot program will provide $1,000 to U.S. citizens born between January 1, 2025, and December 31, 2028, for whom accounts are opened. During the growth period, contributions can come from five sources, according to a December 2 notice from the Treasury:

1. The $1,000 federal pilot payment;
2. “Qualified general contributions” by states, nonprofits or tribal governments for defined groups of children;
3. Employer contributions of up to $2,500 per year under new Section 128 of the Internal Revenue Code, “Trump Account contribution programs”;
4. Rollovers from a previous Trump account; and
5. Voluntary contributions by parents or others, up to $5,000 per year, indexed for inflation after 2027.

Isaacson says the government shutdown from October 1 through November 12 likely kept the Treasury from making progress during a “critical time” to get the accounts up and running. The December 2 notice was the “first big announcement since OBBBA passed,” she says.

According to Notice 2025-68, parents, guardians, adult siblings or grandparents—in that order of priority—may open one account per child using the new IRS Form 4547 or an online application. The notice also stated that the IRS and Treasury Department “intend to propose regulations providing guidance” regarding the accounts.

Each account will be overseen by a financial institution chosen by the Treasury to serve as the trustee. The account’s “responsible party”—typically the adult who opened it—can select among the approved investment options—the S&P 500 or another index composed of stock primarily of U.S.-based companies—and manage rollovers.

The notice requested that comments on aspects of Trump accounts included within it be submitted by February 20, 2026. Isaacson says she expects additional guidance from the Treasury before that date, based on a “tease” within the notice:

“Comments received will be considered in drafting the forthcoming proposed regulations; however, proposed regulations regarding the election to open an initial Trump [A]ccount and the election for the pilot program contribution … may be issued prior to the end of the comment period,” the notice stated.

Rollovers, Investments and Trustees

Dold says the December 2 notice lacked some details about the administration of Trump Accounts, such as guidance for employers on how they can fund the plans and roll money out of them for their employees.

“If [a parent] contributes to a child’s account, [the contribution] has basis, and [they] can’t automatically roll it into [the child’s] 401(k),” explains Dold. “You can’t take IRA money that is not taxable and put it into a 401(k). Hopefully that will change.”

The industry is still waiting for guidance on what trustees must do if the annual fees and expenses on a participant’s investments change and exceed the 10 basis points, stated in the notice, Dold says—but she has heard talk of a potential safe harbor. Within a “reasonable time period,” trustees will likely have to sell an ineligible fund and reinvest it in a default fund that meets the 10 bps requirement, she says.

Isaacson says it is not entirely clear yet how accounts will be set up. The IRS release for its December 2 notice linked to a draft version of Form 4547. What is not clear is whether the form will be used to establish all Trump Accounts or pilot accounts only, she explains.

In addition, “who will serve as the trustee for the accounts?” Isaacson asks. She says there has not been a public process, such as a request for information, through which the Treasury has sought comment on what financial institutions would like to serve.

In October, the Investment Company Institute urged the Treasury to allow a “robust and competitive marketplace for account trustees.” The asset management trade association warned that requiring accounts to be opened only though a single, Treasury-selected provider “would undermine competition and discourage firms from committing resources to the program,” noting that “such an approach risks creating an uneven playing field and concentrating market power in ways that could distort the broader IRA and retirement services landscape.”

“Given … the scale [of Trump Accounts], [the IRS is] absolutely going to need more than one [trustee],” says Isaacson. “Even if [it’s] selecting one trustee for the pilot program, there’s still a massive part beyond the pilot.”

The ICI’s letter also called for the Treasury to use its authority to broaden the eligible investments for the accounts. The push included a suggestion that the Treasury include global equity index funds, as one example.

Regarding permissible investments, according to the notice, “An eligible investment, generally, is a mutual fund or exchange traded fund … that tracks an index of primarily U.S. companies, such as the Standard & Poor’s 500 stock market index, does not use leverage, does not have annual fees and expenses of more than 0.1 percent of the balance of the investment in the fund, and meets other criteria that the Secretary determines appropriate.”

Bill Ryan, managing director and head of retirement solutions at the Carlyle Group, says the “important part is to get [the accounts] funded and [build] momentum.”

“Then when you get scale, you can actually have competition and do interesting investments … all the things that are in the headlines today,” Ryan says.

Matches and Contributions

Ryan—and likely many other Americans—wonder whether there will be any more philanthropic contributions to the accounts, following two big, recent pledges from billionaires. On December 2, Michael and Susan Dell promised $6.25 billion, aimed at providing about $250 to 25 million children. About two weeks later, retired hedge fund manager Ray Dalio and his wife, Barbara, committed $250 per child to be awarded to approximately 300,000 children in Connecticut.

Separately, employers such as BlackRock, BNY, Charles Schwab and Chime have announced they will match the U.S. government’s $1,000 contribution for their employees.

Ryan says there will probably be a “natural affinity” from those employers with robust benefits structures to match or otherwise contribute to an employee’s child’s account, as those companies are likely to have more resources at their disposal.

Some employers may be enticed to contribute as a means to attract and retain employees, says Catherine Collinson, the founding CEO and president of the Transamerica Institute.

“Employers that might be interested … [exist in] industries where the competition for talent is greatest and where there are perceived labor shortages,” Collinson says. They have “a very immediate opportunity [to compete].”

On August 7, slightly more than one month after the OBBBA became law, 60% of employers polled by Mercer during a webcast said they did not know or had not yet considered whether they would make contributions, while 36% said they had already decided not to contribute. Only 0.3% said they were planning to make contributions, and 4% said they were considering doing so.

Dold anticipates most employers will not offer a match initially, preferring the accounts remain “cost neutral.” Employers who offer a match need to be prepared for every employee to take them up on it, she cautions.

Even if employers do not match, Dold and Collinson say they expect the accounts to be popular.

“If somebody were to offer you a tax-free $2,500 raise, I think you would hear an overwhelmingly positive response,” Collinson says. “But if you take it a step further, a $2,500 contribution to your child’s future that will grow on a tax-advantaged basis, potentially all the way until they reach retirement … is not only the gift of $2,500, it’s a gift as to all the future compounding.”

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