U.S. SEC Staff Grants Narrow Form CRS No-Action Relief for Trump Accounts

On May 5, 2026, the staff of the Securities and Exchange Commission Division of Trading and Markets issued a no-action letter to Robinhood Financial LLC and Robinhood Securities, LLC providing limited relief to Robinhood from certain investor disclosure requirements in the context of Trump Accounts, a new type of retirement account created by the One Big Beautiful Bill Act of 2025.¹

Specifically, the SEC staff said it would not recommend enforcement action under Exchange Act Rule 17a-14(c) if Robinhood does not provide Form CRS — a standard customer relationship disclosure document — to parents, legal guardians, or individuals authorized by the U.S. Department of the Treasury opening Trump Accounts for eligible children. The relief applies only while Robinhood serves as the sole broker-dealer and initial trustee for Trump Accounts.

What is Form CRS?

Form CRS is a short relationship-summary disclosure that SEC-registered broker-dealers subject to Rule 17a-14(c) generally must deliver to retail investors before or at specified points, including account opening. The SEC designed Form CRS to help investors compare firms and understand the nature of the services they are receiving. Under SEC rules, firms typically must provide Form CRS when opening a brokerage account for a retail investor.²

What are Trump Accounts?

Trump Accounts were created by the One Big Beautiful Bill Act of 2025 as a specialized form of individual retirement account for eligible children.³ Trump Accounts will be limited to eligible investments, generally broad-based index mutual funds or exchange-traded funds that satisfy statutory requirements, including restrictions on the use of leverage and on annual fees and expenses. Distributions will not be permitted during the account’s “growth period,” which generally runs until the end of the calendar year in which the beneficiary turns 17.

On March 6, 2026, Treasury and the Internal Revenue Service released the first proposed regulations implementing Trump Accounts. Treasury has selected Robinhood to serve as the sole broker-dealer and initial trustee for the accounts.⁴

What relief did the SEC staff provide?

As noted, the SEC staff indicated that it would not recommend enforcement action if Robinhood refrained from providing a Form CRS in the context of the opening of a Trump Account. The SEC staff’s relief is narrow and fact-specific. It applies only to Robinhood’s role as sole broker-dealer and initial trustee for Trump Accounts and only to the Form CRS delivery requirement under Rule 17a-14(c). The letter does not address other federal or state laws, self-regulatory organization rules, or other regulatory obligations.

In granting the relief, the staff relied on the facts and representations in Robinhood’s request letter, including the following:

• Authorized individuals will not choose among competing broker-dealers, account types, or service models while Robinhood serves as the designated provider. The request also states that Trump accounts cannot be transferred to another broker-dealer while Robinhood acts as sole broker-dealer and initial trustee.
• Robinhood will not collect commissions, account-level fees, or other compensation directly or indirectly from Trump Accounts, although the request letter states that Robinhood will be compensated under separate agreements involving the Financial Agent, Treasury, and Robinhood Markets, Inc.
• Robinhood will not make recommendations, offer proprietary or affiliated products, or cross-market other products or services while acting as the initial trustee.

Robinhood also represented that instead of delivering Form CRS, it will provide disclosures tailored to Trump Accounts. According to Robinhood’s request, the disclosures will address

• the account’s limited investment scope
• the absence of account-level fees and advice
• account functionality

Additionally, the disclosures will provide a link to the Financial Industry Regulatory Authority’s BrokerCheck website. Individuals opening accounts also will be required to acknowledge key investment and account restrictions.

What this means to you

The SEC staff position should not be viewed as a broad exemption from Form CRS requirements. The relief is limited to Robinhood, Trump Accounts, the period during which Robinhood serves as the sole broker-dealer and initial trustee, and the specific facts described in Robinhood’s request letter.

The staff also expressed no view on any other questions the activities may raise, including the applicability of other federal or state laws or rules or any self-regulatory organization rules.

Still, the letter may provide limited insight into how the staff could analyze Form CRS delivery questions for similarly constrained, programmatic brokerage relationships, but any application beyond the Robinhood facts would require separate analysis.

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Sidley is closely monitoring developments. Please contact us if you have any questions or would like assistance navigating regulatory developments related to Trump Accounts.

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1 Letter from Emily Westerberg Russell, Chief Counsel, Div. of Trading & Mkts., SEC, to John S. Markle, Counsel for Robinhood Financial LLC & Robinhood Securities, LLC, at 1 (May 5, 2026).
2 17 C.F.R. §§ 240.17a-14(c)(1), 275.204-5(b)(1).
3 Pub. L. No. 119-21, § 70204, 139 Stat. 72, 179-88 (2025) (codified in relevant part at I.R.C. § 530A).
4 Letter from John S. Markle, Counsel for Robinhood Financial LLC & Robinhood Securities, LLC, to Emily Westerberg Russell, Chief Counsel, Div. of Trading & Mkts., SEC, at 1 n.1 (May 5, 2026).