The National Association of Insurance and Financial Advisors (NAIFA) has submitted formal comments to the Internal Revenue Service regarding the implementation of Section 530A Trump Accounts, as outlined in IRS Notice 2025-68.
NAIFA’s submission included recommendations on increasing investment flexibility and clarifying the accounts’ status under ERISA. However, the organization stressed that including financial advisors in both the rollout and ongoing management of Trump Accounts is crucial for their long-term success.
“Trump Accounts represent a meaningful opportunity to promote early savings and financial security from birth,” said NAIFA President Christopher L. Gandy, LACP. “But accounts alone do not build wealth; relationships, education, and disciplined guidance do. NAIFA members stand ready to help families use these accounts responsibly and strategically to secure brighter financial futures for their children.”
In its comments, NAIFA suggested that current restrictions limiting Trump Account investments mainly to index funds and ETFs should be reconsidered. The association argued that broader investment options would allow advisors to better tailor strategies for individual needs.
“Restricting access to broader investment options limits customization and prevents advisors from tailoring strategies to the specific needs of the individual,” Gandy said. “Financial experts are positioned to responsibly advise their clients on the multitude of investment options available to them and then use that knowledge to maximum value and returns over time.”
NAIFA also asked for clear confirmation that Trump Accounts are not subject to ERISA rules. The group noted that while employers may contribute, they do not establish or maintain these accounts, so treating them as employer-sponsored benefit plans could lead to administrative challenges, increased litigation risk, and reduced employer participation.
The association highlighted the importance of professional guidance for families—especially those with lower or middle incomes—to navigate complex regulations and make informed long-term decisions about savings.
NAIFA members can help by simplifying contribution and withdrawal rules, integrating Trump Accounts into overall financial planning alongside other tools like 529 plans or retirement savings, encouraging regular contributions for compound growth benefits, initiating conversations with new parents or community groups about family-focused benefits, and providing ethical advice according to professional standards.
Without clear opportunities for advisor involvement, NAIFA warned that families might face confusion or unintended tax issues. Including financial professionals could turn Trump Accounts into a starting point for lifelong discussions about financial security.
NAIFA praised Treasury Department and IRS efforts in seeking public feedback on this issue and reaffirmed its willingness to collaborate further so that Trump Accounts can expand access to long-term savings opportunities for future generations.



