Trump Accounts, 91 Fed. Reg. 63200 (Sept. 30, 2026) (codified at 26 C.F.R. pt. 1) (TD 10056)

Trump Accounts, 91 Fed. Reg. 63215 (proposed Sept. 30, 2026) (to be codified at 26 C.F.R. pt. 1) (CC-00226466-26)

U.S. Dep’t of the Treasury, Press Release SB-0642: Treasury Announces the Completion of Automatic Enrollment Today for Trump Accounts (Oct. 1, 2026)

Executive Summary and Scope of Treasury Announcement

On October 1, 2026, the Department of the Treasury issued Press Release SB-0642, officially announcing the nationwide completion of automatic enrollment for Trump accounts under Internal Revenue Code (IRC) Section 530A. Enacted pursuant to Section 70204 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), Section 530A establishes specialized, tax-advantaged traditional Individual Retirement Accounts (IRAs) maintained for eligible minors during a statutorily defined growth period ending on December 31 of the calendar year in which the beneficiary attains age 17.

The October 1 announcement marks a historic operational milestone in federal wealth-building policy. Through a single nationwide bulk election, Treasury successfully established auto accounts for more than 60 million American children who had not previously enrolled via manual opt-in elections, bringing total program coverage to approximately 73.3 million eligible minors across 44 million families. In announcing the completion of funding and account setup, Treasury Secretary Scott Bessent emphasized:

“Millions of children have already enrolled in Trump Accounts. With automatic enrollment, over 60 million more eligible children now have an account ready to be claimed... This is a transformative milestone in the Trump Administration’s effort to give every American child the opportunity to build generational wealth and jump-start their financial future.”

For tax practitioners, CPAs, and Estate Planning attorneys, the announcement shifts focus from initial account establishment to the technical administrative procedures governing how authorized parties claim these auto accounts, unlock the one-time $1,000 government seed contribution under IRC Section 6434, enable tax-free employer contributions under IRC Section 128, and navigate the dual regulatory framework created by Treasury Decision 10056 (26 CFR §§ 1.530A-1T, 1.530A-7T) and Notice of Proposed Rulemaking CC-00226466-26.

Architecture of Automatically Enrolled Accounts and Master Group Trust Integration

The technical execution of the October 1 automatic enrollment rests on the dual-layer administrative framework codified in 26 CFR § 1.530A-1T(d)(2) and (e). Under Section 530A(b)(2)(C)(i), Congress authorized the Secretary of the Treasury to execute an election to establish an initial Trump account for any eligible individual who has not attained age 18 before the end of the calendar year, has been issued a valid Social Security Number under Section 24(h)(7), and for whom no prior election was submitted under Section 530A(b)(2)(C)(ii).

To execute bulk enrollment while respecting strict statutory tax privacy mandates, Treasury established a master group trust architecture under Revenue Ruling 81-100, 1981-1 C.B. 326. Under IRC Section 6103, identifying details regarding eligible children obtained from tax returns or Social Security Administration records constitute highly protected tax return information. Disclosing this information to commercial financial institutions or nonbank trustees prior to identity authentication would violate Section 6103.

Treasury resolved this conflict by structuring auto accounts under 26 CFR § 1.530A-1T(e)(3) such that each individual auto account holds an undivided proportionate beneficial interest in a master group trust established by the Secretary, which is tax-exempt under IRC Section 408(e). In the preamble to TD 10056, the IRS detailed the legal justification for this structure:

“The master group trust addresses the concerns reflected in the prior § 1.530A-1 NPRM about disclosure of return information because investments are held and administered at the master-group-trust level. Thus, the trustee of the master group trust can execute transactions for the trust without receiving or disclosing account-identifying return information for each account beneficiary in connection with each transaction. Return information used to identify eligible individuals and establish auto accounts is retained in a safeguarded environment by the Secretary and his financial agent authorized to receive that information on the Secretary’s behalf.”

Under 26 CFR § 1.530A-1T(e)(1), the Secretary serves as the initial “responsible party” for all auto accounts. During this passive, auto-enrolled status, an auto account’s sole investment is its equitable interest in the master group trust (§ 1.530A-1T(e)(3)(i)). Furthermore, under § 1.530A-1T(e)(2), auto accounts are subject to strict contribution restrictions: they may accept only qualified general contributions from government or philanthropic donors under Section 530A(f) and $1,000 pilot program contributions under Section 6434. Ordinary family deposits and Section 128 employer contributions are strictly prohibited until an authorized party claims the account.

Procedural Protocol for Authorized Parties to Claim Control of Accounts

To transition an auto account from passive Treasury administration to active parental or beneficiary control, an authorized party must execute the formal claiming protocol prescribed in 26 CFR § 1.530A-1T(f) and highlighted in Treasury’s October 1 announcement.

Authorized Claimants and Identity Authentication

Under 26 CFR § 1.530A-1T(f)(1), a claim may be filed by a parent or legal custodian possessing authority under applicable state law to manage the minor account beneficiary’s property or financial affairs, or by an account beneficiary who has attained legal capacity under state law. Treasury instructed parents to initiate claims through the newly launched, official Trump Accounts mobile application (available on iOS and Android) or via the secure web portal at TrumpAccounts.gov.

Because account details remain protected return information under IRC Section 6103, the mobile app claiming workflow requires the claimant to complete a rigorous three-step legal verification:

Identity Authentication: The claimant must independently authenticate their personal identity.
Proof of Legal Authority: The claimant must establish legal entitlement under applicable state law to act on behalf of the minor beneficiary.
IRC Section 6103 Disclosure Consents: The claimant must establish statutory entitlement to inspect decedent or minor tax records under Section 6103(e) and execute formal written consents under Section 6103(c) authorizing Treasury to disclose return information to the designated receiving trustee.

As Treasury explained in the preamble to TD 10056:

“In addition, a person seeking to claim an auto account must independently submit the information required by the Secretary, authenticate the person’s identity, establish the person’s legal authority to act with respect to the account and to receive the account beneficiary’s return information, and execute any consent required for disclosures necessary to process the claim and transfer the account balance. This process permits an authorized person to claim and control the account without disclosing protected account information before the person’s legal authority to that information has been established.”

Qualified Rollover Mechanics and Account Activation

Under 26 CFR § 1.530A-1T(f)(1), claiming an auto account during the beneficiary’s growth period results in a direct trustee-to-trustee transfer of the entire auto account balance pursuant to IRC Section 530A(e). The transfer must be directed to either:

A claimed initial Trump account maintained by a Treasury-designated trustee pursuant to Section 530A(g); or
A rollover Trump account established at a commercial financial institution selected by the parent.

Under 26 CFR § 1.530A-1T(d)(3) and (f)(1), submitting a claim via the mobile app does not, by itself, complete account establishment. The receiving account must be formally “activated” by the parent executing the written account agreement with the receiving trustee. Funds remain in the master group trust until receiving account activation is complete.

Becoming Responsible Party and Managing Multiple Claims

Upon activation of the receiving account, the claiming guardian becomes the official “responsible party” under 26 CFR § 1.530A-1T(f)(4). In this capacity, the guardian obtains statutory authority to select among eligible index-tracking equity funds (IRC § 530A(b)(3)), direct future trustee-to-trustee qualified rollovers (§ 530A(e)), authorize qualified ABLE account rollovers during the year the beneficiary turns age 17 (§ 530A(d)(4)), and designate successor responsible parties.

Under 26 CFR § 1.530A-1T(f)(2), if competing claims are submitted by different individuals for the same child’s auto account, the legal responsible party is determined by order of activation: the responsible party will be the first authorized claimant who successfully activates the receiving account with the trustee.

Unlocking Seed Funding, Employer Contributions, and Tax-Exempt Philanthropy

Treasury’s October 1 announcement underscored that claiming an automatically enrolled Trump account is the mandatory administrative trigger to unlock substantial financial benefits.

The $1,000 Government Seed Contribution under IRC Section 6434

Under IRC Section 6434, enacted under OBBBA, Congress established the Trump Accounts Contribution Pilot Program. Section 6434(a) provides a $1,000 one-time federal payment treated as a tax payment for qualifying children born after December 31, 2024, and before January 1, 2029, who are U.S. citizens with valid Social Security Numbers (§ 6434(c)).

Under 26 CFR § 1.530A-1T(e)(2) and Treasury’s operational guidance, while Treasury credits pilot program allocations to auto accounts, full activation and receipt of the $1,000 seed contribution requires the parent or guardian to claim the account via the mobile app. Crucially, Section 6434(f) provides absolute statutory protection for these seed funds: pilot program payments cannot be reduced or offset pursuant to IRC Section 6402 for back taxes, child support arrears, or federal debt collection, nor can they be subjected to administrative levy.

Tax-Free Employer Contributions under IRC Section 128

Under IRC Section 128(a), gross income of an employee does not include amounts paid by an employer as a contribution to a Trump account maintained for the employee or any dependent of the employee. Under Section 128(b)(1), the annual exclusion limit is set at $2,500 per employee (indexed for inflation post-2027 under § 128(b)(2)).

To qualify for exclusion, contributions must be made pursuant to a separate written plan meeting nondiscrimination requirements similar to dependent care assistance programs under Section 129(d) (§ 128(c)). However, because passive auto accounts cannot accept employer deposits (§ 1.530A-1T(e)(2)), employees must claim their child’s Trump account and provide receiving account routing instructions to their employer’s payroll department before Section 128 plan contributions can be deposited.

Family Contributions and Philanthropic General Contributions

Once an auto account is claimed, family members and friends may make annual non-deductible cash contributions up to the statutory limit of $5,000 per calendar year (IRC § 530A(c)(2)). These contributions create investment in the contract (basis) under IRC Section 72 (§ 530A(d)(2)).

Additionally, claimed accounts remain eligible to receive qualified general contributions funded by state governments, Tribal nations, or 501(c)(3) charitable organizations under Section 530A(f) and 26 CFR § 1.530A-7T. Under IRC Section 139J, qualified general contributions are completely excluded from the beneficiary’s gross income.

Evolution from Form 4547 Opt-In to Digital App Claiming

The Treasury announcement and temporary regulations reflect a complete shift in administrative strategy regarding account creation.

Under the prior Notice of Proposed Rulemaking published on March 9, 2026 (REG-117270-25), Treasury had originally designed account setup around an affirmative paper opt-in election using Form 4547 (Trump Account Election(s)) pursuant to Section 530A(b)(2)(C)(ii). In CC-00226466-26, Treasury formally withdrew REG-117270-25.

In the preamble to TD 10056, Treasury explained that public comments and empirical economic analysis demonstrated that a paper opt-in model would result in severe under-enrollment. Precedent from Maine’s Alfond Grant program indicated that opt-in paper elections achieved only ~40% to 50% participation, disproportionately leaving low-income families without accounts. Table 1 of TD 10056 revealed that as of July 30, 2026, only 5.6 million electronic Forms 4547 had been processed out of 73.37 million eligible children—representing less than 8% national coverage.

By replacing paper opt-in elections with bulk automatic enrollment under 26 CFR § 1.530A-1T(d)(2), Treasury achieved near-100% account creation as of October 1, 2026. Under § 1.530A-1T(d)(2)(ii), any Form 4547 filed prior to October 1 that was not fully activated resulted in the automatic creation of an auto account. Today, paper Form 4547 is rendered largely obsolete, reserved only for rare administrative exceptions where automated Treasury matching is unsuccessful (§ 1.530A-1T(d)(1)(ii)). All routine account claiming, identity authentication, and trustee selection are now handled digitally via the Trump Accounts mobile app and web portal.

Legal Status, Taxpayer Reliance, and Administrative Procedure Act Justification

Tax professionals advising clients must understand the binding legal effect of the newly released regulations.

Binding Effect of Temporary Regulations vs. Proposed Rules

TD 10056 promulgated temporary regulations under 26 CFR §§ 1.530A-1T and 1.530A-7T, effective immediately upon publication on September 29, 2026, and applicable to taxable years beginning on or after January 1, 2026 (§§ 1.530A-1T(g), 1.530A-7T(f)). Under IRC Section 7805(e)(2), these temporary regulations carry the full force of law and will remain binding for three years, expiring on September 30, 2029.

Conversely, CC-00226466-26 contains identical proposed text for 26 CFR §§ 1.530A-1 and 1.530A-7, which will apply only to taxable years beginning on or after the publication of final regulations. Crucially, Treasury included an explicit non-reliance directive in the preamble to CC-00226466-26:

“Taxpayers may not rely on these proposed regulations. See §§ 1.530A-1T and 1.530A-7T.”

Practitioners must rely exclusively on the temporary regulations (§§ 1.530A-1T and 1.530A-7T) when advising clients, trustees, and employers.

Administrative Procedure Act Compliance

Treasury justified issuing immediately effective temporary regulations without prior notice and comment under the Administrative Procedure Act (APA) “good cause” exception (5 U.S.C. 553(b)(3)(B)). Treasury determined that advance notice-and-comment was impracticable and contrary to the public interest because delaying account creation rules would prevent the Secretary from administering auto accounts, block children from receiving $1,000 seed contributions under Section 6434, and shorten the investment growth period. Treasury also waived the 30-day delayed effective date under APA Section 553(d)(3) and Section 808(2) of the Congressional Review Act (5 U.S.C. 808(2)), making TD 10056 effective immediately.

Prepared with assistance from Gemini Notebook.