Trump Accounts Contribution Pilot Program (REG-117002-25)

The American Bankers Association (ABA) appreciates the opportunity to respond to a proposed rulemaking by the Internal Revenue Service (IRS) concerning individual retirement accounts (IRAs) established for the exclusive benefit of an eligible individual or the individual's beneficiaries under section 530A of the Internal Revenue Code (Trump accounts). Specifically, the rulemaking concerns the contribution pilot program under which the Trump accounts of eligible children can receive $1,000 pilot program contributions. Our members support additional avenues for providing financial education, saving money, and building long-term financial security for children and teenagers. We believe Trump accounts are an important tool to support long-term wealth building for future generations within local communities. We recommend that the IRS clarify when and how a $1,000 pilot program contribution could be made to a rollover Trump account. And, request that the IRS consider requiring the $1,000 pilot contributions be made when the initial Trump account is opened for eligible children, or prior to when a qualified rollover contribution is made to a rollover Trump account at a different institution/trustee. Thank you for your consideration of our views and recommendations.