DOL’s guidance gives employers room to fund or facilitate Trump Account contributions without creating an ERISA plan.

When Congress created Trump accounts under the One Big Beautiful Bill Act, one of the questions employers quickly focused on is whether providing employees with a plan under which contributions may be made to Trump accounts would constitute

Enacted into law as part of the 2025 budget reconciliation act and as initially described in an earlier Thompson Hine blog post, Trump accounts will provide a new private savings vehicle for the exclusive benefit of eligible minor children. The IRS recently issued Notice 2025-68 to provide additional detail on Trump accounts while proposed