Trump Account Written Program Checklist for Employers

A strong Trump Account written program should do more than repeat the statute. It should define the decisions payroll, HR, finance, tax, legal and outside providers need in order to operate the program consistently.

What the written program should control

• Program purpose and effective date — identify the employer, program year, approval date and who owns administration.
• Eligibility rules — define which employees are eligible and how eligibility is determined each contribution cycle.
• Beneficiary rules — state whether contributions may be made for employees, dependents, or both, and what beneficiary data must be collected.
• Contribution formula — document amount, frequency, limits, funding timing and any proration rules.
• Section 128 limit control — show how the employer will prevent excess employee-level contributions.
• Certification process — describe employee certifications, intake method, retention and change handling.
• Account verification — document how the employer will reasonably verify that the destination account is a Trump Account.
• Nondiscrimination process — assign the test owner, testing data source, calendar and remediation workflow.
• Reporting and notices — define employee notice, annual statement and payroll reporting responsibilities.
• Error correction — describe rejected payments, excesses, stale account data and trustee notices when a payment no longer qualifies.

Keep the written program aligned with payroll

The written program should match the actual operating process. If the plan says contributions are made quarterly, but payroll processes one-off payments by request, the employer has created a control gap. Tie every written provision to a field, owner, review step or evidence record.

Design for provider handoffs

Trump Account contributions may involve payroll systems, trustees, benefits administrators and employee self-service intake. The written program should specify which party creates the funding file, who validates account information, how errors are returned and where confirmation is stored.

Source records to retain

Employers should retain the approved written program, employee eligibility data, certifications, account-verification support, contribution files, trustee confirmations, nondiscrimination workpapers, notices, annual statements, W-2 support and correction logs.

Related Trump Account employer resources

Primary sources

• IRS proposed regulation announcement
• Federal Register proposed rule REG-101355-26

Educational implementation guidance only; not legal, tax, ERISA, payroll, benefits, investment or accounting advice.