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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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Trump Accounts are tax-advantaged investment accounts for U.S. children under age 18. Eligible children born after 2024 and before 2029 are eligible for a $1,000 pilot program contribution from the Department of the Treasury. Older eligible children are not eligible for the pilot program contribution but otherwise are eligible to have Trump Accounts established for them to which employer and other contributions may be made. Contributions may begin July 4, 2026. Initial guidance has been published, and additional guidance is expected before contributions may be first made.

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-- May determine that employees are interested in establishing Trump Accounts for eligible children and if so may wish to facilitate their doing so with an employer program -- Employer programs may permit employees to make pre-tax salary reduction contributions to dependents’ Trump Accounts through a cafeteria plan and/or may provide for tax-free nonelective contributions to Trump Accounts for employees or their dependents -- Total Trump Account employer program contributions limited to $2,500 per employee annually (limit to be adjusted after 2027)

-- Although Treasury selects the initial trustee(s), it may be desirable to consider whether to serve as a trustee of rollover Trump Accounts including due to the opportunity to ultimately gain new wealth management clients and assets under management -- Any person approved by the IRS as of December 31, 2025 to be a nonbank trustee of an IRA is automatically approved to be a nonbank trustee of a rollover Trump Account -- Although employer program and certain contributions are subject to separate annual limits ($2,500 and $5,000, each adjusted after 2027), pilot program and eligible contributions made pursuant to charitable or governmental arrangements are unlimited

Eligible Tax-Exempt Organizations and Governmental Entities

-- May decide to apply to Treasury to make a qualified general contribution to Treasury that if approved Treasury would divide evenly by the number of eligible children in the qualified class and contribute that amount to each of their Trump Accounts -- Qualified class generally refers to eligible children with Trump Accounts (account beneficiaries) in a geographic area (the entire country, a state, or other area in which at least 5,000 account beneficiaries reside) that is designated by Treasury -- There is no annual or other limit on the amount of a qualified general contribution and accordingly no limit on the resulting amounts that may be contributed to each account beneficiary resulting from one or more qualified general contributions

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-- DOL to specify how employer programs are exempt from ERISA -- Treasury and DOL expected to specify whether employers may limit the Trump Account trustee(s) to which they will make contributions -- Treasury to specify how employer contributions (including salary reduction) are made to Trump Accounts by the employer and the extent of employer reporting requirements, if any -- Treasury to specify how employer programs are to be coordinated with applicable cafeteria plan requirements and how to meet applicable Internal Revenue Code nondiscrimination requirements

-- Treasury will select the financial institution(s) to serve as trustees for initial Trump Accounts (every Trump Account must be opened with a selected institution as trustee) -- Existing approved IRA trustees are eligible trustees of rollover Trump Accounts and are not subject to this selection process -- Trustees must provide annual reporting on contribution sources, distributions, fair market value, and basis; transferring trustees must report that information to the receiving rollover Trump Account trustee -- Trustees must select a default investment, must offer only eligible investments and must monitor whether an investment remains eligible -- Trustees must enforce applicable contribution caps; Treasury is considering a staging safe harbor under which trustees accept contributions into a general account and remit to a Trump Account only to the extent determined to be a permissible contribution -- Trump Account governing documents must meet certain requirements

-- Treasury to specify how to apply to make a qualified general contribution -- Treasury to specify how the resulting Trump Account contribution will be made with respect to each account beneficiary

Proposed regulations and additional other guidance are expected to be issued in the near term, and likely will be published in discrete pieces during 2026 that in the aggregate will address, at a minimum, each of the considerations outlined above. At the time of publication, additional guidance regarding employer plans and other aspects of these accounts, such as special rules governing Trump accounts compared to traditional IRAs, has not been released.

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Employers interested in making contributions to Trump Accounts or facilitating employee contributions to Trump Accounts may wish to begin planning now to identify open questions as well as internal resources and assistance that may be needed from service providers, in particular if there is a desire to have a program in place under a cafeteria plan in time for open enrollment near the end of 2026.

Existing IRA trustees considering whether to serve as rollover Trump Account trustees may wish to identify all open questions regarding trustee responsibilities in preparation for expected guidance and may wish to reach out to Treasury (either in writing or in a meeting) to discuss those questions and provide any feedback to Treasury before that guidance is published in particular to the extent that educating Treasury as to any practical considerations and/or proposed solutions may impact the desirability of serving as a rollover Trump Account trustee.

Eligible philanthropic organizations and governmental entities considering whether to make unlimited contributions to a qualified class of Trump Account beneficiaries may wish to start considering what the corresponding qualified general contribution might look like, both in amount as well as which account beneficiaries may be covered, and may wish to reach out to Treasury as part of that process.

Please contact <a href="https://www.thompsonhine.com/professionals/dominic-dematties/">Dominic DeMatties</a> or <a href="https://www.thompsonhine.com/professionals/eric-d-slack/">Eric Slack</a> with any questions. More information about Trump Accounts can also be found on Thompson Hine’s ERISA Litigation &amp; Compliance blog: <a href="https://www.erisalitigation.com/2025/12/trump-accounts-on-the-menu-a-new-cafeteria-plan-option-other-details-from-initial-treasury-guidance/" target="_blank" rel="noreferrer noopener">Trump Accounts on the Menu: A New Cafeteria Plan Option, Other Details from Initial Treasury Guidance</a>.

https://admin.thompsonhine.com/wp-content/uploads/2026/04/Thompson-Hine-Business-Law-Update-April-2026.pdf

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This newsletter may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgement of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel.

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Trump Accounts: Opportunities and Considerations for Employers, Financial Institutions, and Philanthropic Organizations

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