On April 6, 2026, the Treasury Department announced key infrastructure details for the implementation of the new Trump Accounts program, designating The Bank of New York Mellon Corporation (BNY) as the financial agent to manage the initial accounts. For CPAs and Enrolled Agents advising families with eligible children, understanding this initial setup—as well as the strict mechanics for rolling these accounts over to a successor trustee under IRC § 530A and Notice 2025-68—will be critical as the program's July 4, 2026, contribution launch date approaches.

The Initial Trustee and Trump Accounts App

Under its statutory authority to designate financial agents in a fiduciary capacity, Treasury selected BNY to support the Trump Accounts program. In turn, BNY has partnered with Robinhood, which will serve as the brokerage and the initial trustee for these accounts.

To facilitate the rollout, BNY and Robinhood are working with the National Design Studio to develop a secure, custom "white-label" Trump Accounts app, providing an intuitive platform for families to access and manage their funds. Treasury will retain ultimate control over the app and the operations for these initial accounts, aligning with the statutory requirement that the initial Trump account be created or organized by the Secretary of the Treasury for the exclusive benefit of the eligible individual.

Moving to a Successor Trustee: "Rollover Trump Accounts"

While the initial accounts are established and managed centrally, the IRC and IRS Notice 2025-68 provide a framework for a "responsible party" (the individual who originally elected to open the account, such as a parent or legal guardian) to move the funds to a different trustee. A subsequent account established during the beneficiary's "growth period" (before they turn 18) is statutorily referred to as a rollover Trump account.

If a client wishes to move their child's funds to a different institution, practitioners must guide them through several strict operational rules:

Eligible Successor Trustees: Unlike the initial trustee, trustees of rollover Trump accounts are not subject to the Treasury's selection process. The successor trustee must simply be a bank (as defined in IRC § 408(n)) or an IRS-approved nonbank trustee. Notably, any entity already approved by the IRS to be a nonbank IRA trustee as of December 31, 2025, is automatically approved to be a Trump account trustee, provided they submit a written notification of this change to the IRS.
The "Qualified Rollover Contribution" Requirement: A rollover Trump account can only be established after the initial account is opened and must be funded first and exclusively via a "qualified rollover contribution". A qualified rollover contribution is strictly defined as a direct trustee-to-trustee transfer of the entire account balance from the existing Trump account.
Only One Account Permitted: Because a rollover requires moving the entire balance, an individual may only have one funded Trump account open at any given time.
Closing the Old Account & Trailing Dividends: Once the qualified rollover contribution is made, the transferring Trump account cannot accept any new contributions and must be closed within a reasonable period of time. If the old account receives any trailing dividends after the transfer, the transferring trustee is required to promptly forward those funds to the new rollover account, where they will be treated as part of the original qualified rollover contribution.

Compliance and Reporting Requirements for the Transfer

Moving to a successor trustee triggers unique reporting requirements under IRC § 530A(i) that differ from standard IRA reporting. CPAs and EAs should verify that the receiving institution's compliance systems are prepared for the following:

Transferring Trustee Reporting: When moving the funds, the transferring trustee must promptly provide a report directly to the receiving trustee (not to the Treasury or the beneficiary) confirming that the transferring account is a Trump account. This report must include the account's basis information and detail any contributions made during the current calendar year. This data is essential for the new trustee to accurately track basis and strictly enforce the $5,000 annual limit on non-exempt contributions.
Receiving Trustee 30-Day Rule: The receiving trustee is subject to a strict deadline. Within 30 days of receiving a qualified rollover contribution, the successor trustee must submit an electronic report to the Treasury Department containing the account beneficiary's name, address, and SSN, alongside the new trustee's name, address, account number, and routing number.

While Treasury's partnership with BNY and Robinhood provides a streamlined starting point for millions of eligible children, the statutory framework ensures families maintain the flexibility to roll their child's Trump Account over to another qualifying financial institution. Tax professionals must ensure clients follow the "entire balance" trustee-to-trustee transfer rules to preserve the tax-advantaged status of the account and prevent inadvertent compliance failures.

Prepared with assistance from NotebookLM.