SEC Grants Broker-Dealer No-Action Relief from Delivering Required Client Disclosures for Trump Accounts

On May 5, 2026, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Trading and Markets (the “Staff”) issued a no‑action letter stating that it would not recommend enforcement action under Exchange Act Rule 17a‑14(c) if Robinhood Financial LLC and Robinhood Securities, LLC (collectively, “Robinhood”) do not deliver Form CRS (Customer Relationship Summary) in connection with the opening of  “Trump Accounts.”

The Staff’s position indicates that the purpose of Form CRS is not fulfilled when broker-dealers manage highly constrained account programs dictated by the federal government.

Background

Trump Accounts were created by the “One Big Beautiful Bill Act of 2025” (OBBA, P.L. 119-21) as a new type of individual retirement account (IRA) for children under the age of 18. Trump Accounts may be established by parents, guardians, or other authorized persons for the benefit of a child with a valid Social Security Number by filing IRS Form 4547. Families, friends and employers can contribute up to $5,000 per year, per child to the account. Once a child turns 18, the funds in the account may be accessed without penalty for qualified expenses like education, a first home purchase, or starting a business. As part of a pilot program, the federal government will contribute a one-time deposit of $1,000 to each account for children who are U.S. citizens and born between January 1, 2025, and December 31, 2028.

By design, Trump Accounts are subject to statutory and contractual constraints during the account’s “growth period,” the time between the account’s opening and the date the child turns 18. The OBBA provides that, as clarified by Internal Revenue Bulletin: 2025-52, investments during this growth period are limited to mutual funds or ETFs tracking a qualified index with at least 90% U.S. company weighting (e.g., the S&P 500), that do not use leverage, have annual fees below 0.1%, and are generally subject to restrictions on leverage and early distributions. These features distinguish Trump Accounts from Roth IRAs, particularly given that Trump Accounts offer tax-deferred, rather than tax-free growth, treat withdrawals as ordinary income, and do not require the beneficiary to have earned income.

The U.S. Treasury (the “Treasury”) designated Robinhood to serve as the sole broker‑dealer and initial trustee for all Trump Accounts during their growth period. As a result, authorized individuals do not select among competing brokerage firms, account types, or service models when opening a Trump Account. In its roles as sole broker‑dealer and initial trustee, Robinhood is explicitly prohibited from receiving fees or commissions and marketing additional products or services to Trump Account holders.

This centralized structure reflects the Treasury’s implementation decision to use a single, uniform platform to simplify administration, reduce costs, and ensure consistent oversight of a large‑scale federal program. Robinhood was selected to develop a custom “white label” Trump Accounts app in collaboration with the National Design Studio while the Treasury retains control over the accounts. Although the initial setup is centralized, account holders may later roll over their Trump Accounts to other qualified custodians.

The Form CRS Issue

Under Rule 17a‑14(c), SEC‑registered broker‑dealers are generally required to deliver Form CRS to retail investors at or before the opening of a brokerage account. Form CRS is intended to help retail investors understand and compare brokerage and advisory relationships, with particular emphasis on fees, conflicts of interest, standards of conduct, and available alternatives.

Robinhood argued that applying the Form CRS delivery requirement in this context would not advance those objectives. Robinhood highlighted that because Trump Accounts involve no investor choice among firms, no account‑level fees, no compensation‑based conflicts, and no recommendations or advisory services, Form CRS disclosures could confuse account holders and incorrectly suggest the presence of costs, conflicts, or service alternatives that do not exist.

The Staff’s No‑Action Position

Based on the specific facts in Robinhood’s request, the Staff agreed that it would not recommend enforcement action under Rule 17a‑14(c) if Robinhood does not deliver Form CRS when Trump Accounts are opened by authorized individuals.

Several limiting factors likely dictated the Staff’s position, including:

• Robinhood’s role as the sole broker‑dealer and initial trustee selected by the Treasury, rather than by the investor;
• The absence of fees, commissions, recommendations, or material conflicts of interest;
• The standardized, non‑discretionary, and statutorily constrained nature of the accounts; and
• Robinhood’s commitment to provide alternative, tailored disclosures relevant to the Trump account structure.

As with other SEC no‑action letters, the Staff cautioned that its position is strictly limited to the facts presented and could be modified or withdrawn at any time.

Why It Matters

This letter reflects a pragmatic, purpose‑driven application of the SEC’s disclosure regime. The Staff signaled its agreement that investor understanding in a highly constrained setting would not be furthered by requiring Form CRS delivery in this context.

At the same time, the relief is narrow. Firms should not view this letter as signaling broader flexibility around Form CRS delivery obligations for ordinary retail brokerage relationships. The Staff’s position turns on the unique combination of government designation, absence of investor choice, elimination of fees and cross-selling, and the specific nature of Trump Accounts.

Broker-dealers involved in government‑sponsored or similarly constrained account programs should nonetheless take note. Where a brokerage relationship lacks the core attributes Form CRS was designed to address, less onerous, tailored disclosure approaches, supported by careful factual representations, may warrant consideration.

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