The Social Security Administration (SSA) has updated its Program Operations Manual System (POMS) with a new section addressing the treatment of 530A/Trump Accounts under the income and resource rules for Supplement Security Income (SSI). SSA’s new instruction, POMS SI 01120.250, will exempt these accounts from being counted against a person’s income or resources for purposes of SSI eligibility until January 1 of the calendar year that the child turns 18 years old.
530A/Trump Accounts are a new custodial-style Individual Retirement Account (IRA) for minors introduced in 2025 under federal tax law; they can be established and administered by an adult but are owned by the child as the beneficiary. Contributions may be made by parents and others, subject to annual federal contribution limits. During the account’s “growth” period, investment earnings and interest generally accumulate on a tax-deferred basis. The accounts are also subject to a number of age-based rules, including restrictions on distributions and a limited opportunity to roll funds into an ABLE account.
There is also a pilot program that provides a federal contribution of $1,000 in seed money into a 530A/Trump Account for children born between January 1, 2025 through December 31, 2028 only. Parents must elect to receive the contribution when they file their tax return or submit the election through a portal.
There are several key dates relevant to the treatment of a 530A/Trump Accounts under the SSI rules:
- Through December 31 of the year in which the person turns 17, the entire value of the account is exempted from counting as income or a resource for SSI purposes. Distributions during this “growth” period are subject to early withdrawal penalties. POMS SI 01120.250B.1.
- During this same year, a 530A/Trump Account is eligible to be rolled over into an ABLE account as an exception to the distribution rules and ABLE contribution limits. Advocates should confirm the timing and eligibility requirements before advising a rollover. A rollover to an ABLE account may preserve SSI eligibility only if the beneficiary is ABLE-eligible and the transfer is completed within the permitted rollover window for 530A/Trump Accounts. POMS SI 01120.250C.3.
- Beginning January 1 of the calendar year in which the person turns 18, the funds will be counted as either income (for example if an SSI recipient is direct-depositing a paycheck into the 530A/Trump Account) or as a converted resource (such as the deposit of funds transferred from a savings or other account.) POMS SI 01120.250B.2.
The free federal contribution of $1,000 for the subset of children born in 2026, 2027, and 2028 will undoubtedly benefit many families. Some analyses show that even without further investment, the seed money can grow to over $5,000 by age 18. However, the SSI treatment of these accounts is unusually complex and differs significantly from the rules governing other tax-advantage accounts. Other IRAs, and other investment accounts that benefit children, such as 529 accounts, are not exempted from the SSI resource limits despite sharing some features with 530A/Trump Accounts. See e.g., POMS SI 01140.150 (529 accounts as a countable resource for SSI); POMS SI 01120.210 (IRA and other retirement funds as countable resources for SSI). For families surviving on SSI-level income, there is likely to be strong pressure to access these funds during the growth period despite the potential costs, including early-withdrawal tax penalties, tax liability, and a possible SSI overpayment. This special SSI exclusion highlights a broader issue that advocates have long raised: SSI’s resource limits are so low (generally $2,000 for an individual and $3,000 for an eligible couple) that even relatively modest savings can jeopardize eligibility, making it difficult to build financial security over time.
Families of children receiving SSI should pay close attention to how 530A/Trump Accounts will be treated over time, as the favorable treatment for SSI ends abruptly on January 1 of the calendar year in which the child turns 18. With this calendar-year approach, there is considerable potential for confusion among both families and SSA staff regarding how the funds should be categorized, and any actions that families can take to preserve SSI benefits, such as a rollover into a qualified ABLE account. Unlike rollovers from 529 plans to ABLE accounts which are generally governed on contribution-limit rules rather than a beneficiary deadline, a 530A/Trump Account may be rolled over to an ABLE account only during the calendar year in which the beneficiary attains age 17. The rule has the potential to generate significant numbers of overpayments among families who are unaware that the exclusion has ended, or that the time to rollover into an ABLE account is shorter than the general rule.
The National Disability Institute recently published a resource to help families understand 530A/Trump Accounts, with educational videos and flyers. It can be found at this link.
POMS SI 01120.250 was preceded by Emergency Message (EM) 26022 which has since been archived and should not be relied on. The EM had provided similar instructions.
