With member input, the Association submitted comments to the IRS and Treasury Department on proposed rules for employer contributions to Trump Accounts and related nondiscrimination requirements.
The letter welcomed several provisions members had called for earlier this year. These include allowing employers to rely on employee certifications regarding the account beneficiary’s identity, date of birth, and eligibility, use existing Form W-2 reporting, and applying new nondiscrimination testing safe harbors for pilot-match contributions (the $1000 federal government contribution made to newborns) and eligibility classifications.
We also flagged key questions that remain. Employers need clarity on how to verify account validity, coordinate the $2,500 annual contribution limit across multiple employers, handle corrective notices and report contributions through third-party payroll providers.
Finally, we urged Treasury and the IRS to finalize the rules as quickly as possible, given that many members have already announced matching contributions tied to the government’s pilot program and are building their 2027 programs.
We’ll keep members posted as this rulemaking progresses. Read our letter.
