Effective Dates: 7/09/2026 - Present

Identification Number:
SI 01120 TN 105
Intended Audience:See Transmittal Sheet
Originating Office:LP ISP
Title:Identifying Resources
Type:POMS Full Transmittals
Program:All Programs
Link To Reference:
 

PROGRAM OPERATIONS MANUAL SYSTEM
Part SI – Supplemental Security Income
Chapter 011 – Resources
Subchapter 20 – Identifying Resources
Transmittal No. 105, 07/09/2026

Audience

FO/TSC: CS, CS TXVI, CSR, CTE, DRT, FR, OA, OS, RR, TA, TSC-CSR;

Originating Component

ISP

Effective Date

Upon Receipt

Background

A Trump Account (TA) is a tax-advantaged investment account established for children. A type of traditional Individual Retirement Account (IRA), TAs have special rules that change depending on the TA beneficiary's age. TAs are established for the benefit of children and are designed to promote long-term savings. In general, up to $5,000 (adjusted for inflation) can be contributed per year per child, and contributions are invested in low-cost index funds. A federal pilot program provides a $1,000 contribution to the TAs of eligible children born between January 1, 2025, and December 31, 2028. This new policy section provides guidance on how TAs affect SSI eligibility determinations and instructions for documenting these accounts.

Summary of Changes

SI 01120.250 Trump Accounts (TAs)

This is a new policy section.

SI 01120.250 Trump Accounts (TAs)

Public Law No. 119-21, Sec. 70204; Sec. 530A of the Internal Revenue Code; Social Security Act, Sec. 1613

A. Overview of TAs

A Trump Account (TA) is a tax-advantaged investment account established for children. A type of traditional Individual Retirement Account (IRA), TAs have special rules that change depending on the TA beneficiary's age. TAs have two primary periods:

  • •

    Growth period, which begins with the establishment of the initial TA and ends on December 31 of the calendar year in which the TA beneficiary attains age 17; and

  • •

    Post-growth period, which is effective January 1 of the calendar year in which a TA beneficiary attains age 18 and continues thereafter.

TAs are established for the benefit of children and may be funded with first-party and third-party contributions. The parent, guardian, or other authorized individual who completes an election form to open a TA is generally the responsible party and account custodian for the Trump account. Generally, in 2026, up to $5,000 (adjusted for inflation) can be contributed per year per child, and contributions are invested in low-cost index funds. A TA beneficiary may only have one TA funded at a time. A federal pilot program provides a $1,000 contribution to the TAs of eligible children born between January 1, 2025, and December 31, 2028. More information on TAs is available at trumpaccounts.gov.

B. Policy for the income and resource treatment of TAs

The income and resource treatment of TAs changes based on the age of the TA beneficiary.

1. Growth Period

Prior to January 1 of the year the TA beneficiary attains age 18 (growth period):

  • •

    The entire value of a TA is not considered a resource for SSI purposes.

  • •

    Distributions from the TA generally are not permitted. The following do not count as distributions:

    • –

      a rollover to another TA during the growth period;

    • –

      a rollover to an ABLE account when permitted during the calendar year of age 17 attainment (referred to in this section as the "Age 17 TA-ABLE rollover");

    • –

      removal of excess contributions over the annual limit; and

    • –

      distributions upon the death of the TA beneficiary.

  • •

    Contributions made directly to the account are generally not considered income; however, a TA beneficiary cannot avoid income counting by direct depositing funds into a TA. For example, a TA beneficiary could not have their Social Security benefits direct deposited into a TA to prevent them from counting as unearned Social Security income for SSI purposes.

    NOTE: 

    A beneficiary or recipient with a representative payee cannot have their Social Security or SSI payments paid via direct deposit into a TA during the growth period when distributions generally are not permitted. Due to TA distribution restrictions, the representative payee generally would not be able to use the benefits to provide for the beneficiary’s current needs (see GN 00602.001A.2).

For processing instructions during the growth period, see SI 01120.250C in this section.

For additional information on the Age 17 TA-ABLE rollover, see SI 01120.250C.3 in this section.

2. Post-Growth Period

Beginning January 1 of the calendar year the TA beneficiary attains age 18 (post-growth period):

  • •

    The TA is a countable resource. The value of the TA is the amount of money that the TA beneficiary can withdraw from the TA after any penalty for early withdrawal (i.e., early distribution tax).

  • •

    Distributions of TA funds are not income, but a conversion of a resource.

  • •

    Contributions to a TA are income or a conversion of a resource, depending on the source of the contribution.

    For instance:

    • –

      If a TA beneficiary transfers money from their savings account into their TA, the contribution is a conversion of a resource, changing form from a financial institution account resource to a TA resource.

      Example: On 1/15/27, a TA beneficiary transfers $500 of existing account funds from their savings account to their TA. For SSI purposes, on 1/1/27, $500 is counted as a financial account resource. On 2/1/27, $450 is counted as a TA resource ($500-10% early withdrawal penalty=$450).

    • –

      If a TA beneficiary's parent deposits a $1,000 "graduation gift" into the TA, the $1,000 is unearned income in the month of deposit.

    • –

      If a TA beneficiary direct deposits $200 of their paychecks into their TA, each $200 deposit is earned income in the month of deposit.

    Contributions are a countable TA resource beginning the following month.

For processing instructions during the post-growth period, see SI 01120.250D in this section.

C. Development and documentation of TAs during growth period (initial TA establishment through December 31 of the calendar year in which the TA beneficiary attains age 17)

1. Initial claims, redeterminations (RZs), and post-eligibility reports of change for children under age 16

When evaluating resources during initial claims, RZs, and post-eligibility events for SSI applicants or recipients under age 16:

  • •

    Accept the parent, guardian, or payee’s allegations regarding whether a TA has been established for the child and the estimated account value.

  • •

    Record the allegation on an “Other Resources” page by selecting “Trump Account (TA)” from the "Type" drop-down menu. In the “Description” field, include the name of the alleged account custodian (i.e., the “responsible party”), the financial institution administering the account, and the account number if known. See MS 08113.032 for more information on the Other Resources page.

    NOTE: 

    Account custodians are not co-owners; the account beneficiary owns the TA and funds.

  • •

    Enter the entire “Alleged Value” in the "Excluded Amount" field. Use exclusion reason “Trump account (TA).”

  • •

    From the Direct SSR Update Menu (UMEN), select "Diaries," and manually post an RT diary on the Update Diaries (UDIA) screen. Set the maturity date for January 1 of the calendar year the child will attain age 17.

  • •

    Input the following SSR remarks, “RT - [insert maturity date 1/1/xx] Age 17 TA/ABLE Rollover development.”

2. Special development for TA-related RT diaries reaching maturity and for claims, RZs, or resource-related post-eligibility contacts for SSI applicants and recipients aged 16 and 17.

Complete development in SI 01120.250C.2.a through SI 01120.250C.2.d during:

  • •

    RZs related to the maturation of a TA-related RT diary; and/or

  • •

    claims, RZs, or resource-related post-eligibility contacts for claimants aged 16 or 17.

a. Request evidence of TA ownership and balance

To develop or update TA information:

  • •

    Screen for a TA or changes to a TA.

  • •

    Request statements, account records, or other evidence of TA ownership and account value. Store evidence electronically using the Evidence Portal.

  • •

    Document the TA (or update a previously documented TA) on the “Other Resources” page by selecting “Trump Account (TA)” from the "Type" drop-down box.

  • •

    Enter the entire “Alleged Value” in the "Excluded Amount" field. Use exclusion reason “Trump account (TA).”

b. Inform the TA beneficiary and custodian about post-growth period resource counting and the TA-ABLE rollover option

c. Post an Age 18 RT diary to redevelop TA resources prior to the December Goldberg-Kelly (GK) cutoff.

  • •

    From the Direct SSR Update Menu (UMEN), select "Diaries," and manually post an RT diary on the Update Diaries (UDIA) screen to redevelop the TA and potential TA-ABLE rollover. Set the maturity date for December 1 of the calendar year the child attains age 17.

  • •

    Add the following SSR remarks, “RT - [insert maturity date 12/1/xx] Age 18 develop TA/ABLE Rollover and remove TA exclusion effective 1/1/[insert calendar year of age-18 attainment].”

d. Redevelop TA and potential TA - ABLE rollover and post the countable TA value when the Age 18 RT diary matures.

Prior to the GK cutoff in December of the same year (i.e., the year in which the TA beneficiary attains age 17), when the Age 18 RT diary matures, check for a potential TA-ABLE rollover.

  • •

    If rollover is alleged, process according to SI 01120.250C.3 in this section.

  • •

    If rollover is not alleged, redevelop the TA value, and remove the TA resource exclusion effective January 1 of the following year (i.e., the year in which the TA beneficiary attains age 18). If the payee fails to provide information necessary for determining continuing eligibility, see SI 02301.235.

See SI 01120.250D in this section for more instructions on processing TAs in the post-growth period.

3. Age 17 TA - ABLE rollovers

a. Overview of Age 17 TA - ABLE rollovers

During the calendar year a TA beneficiary attains age 17, TAs are eligible for the age 17 ABLE rollover. Through a trustee-to-trustee transfer, the entire balance of the TA may be rolled over to an ABLE account for the TA beneficiary. The rollover is an exception to TA distribution rules and ABLE contribution limits.

Through the TA-ABLE rollover, the TA, which is considered an asset that is not a resource for SSI purposes, is transferred to an ABLE account. Up to $100,000 in an ABLE account may be excluded from resource counting. The TA beneficiary does not receive countable income as a result of this transaction. See SI 01130.740 for more information on ABLE accounts.

Important: All TA funds that are not rolled over to ABLE accounts during this period will become countable TA resources effective January 1 of the following year (i.e., the year in which the TA beneficiary attains age 18).

b. Development and documentation of Age 17 TA - ABLE rollovers

If a TA beneficiary or account custodian alleges a rollover of the TA to an ABLE account:

  • •

    Request evidence that the rollover has been completed (e.g., TA account statement showing zero balance or account closure and ABLE state exchange data or ABLE account statements). Store evidence electronically using the Evidence Portal, as applicable.

  • •

    Update the “Other Resources/TA” and “ABLE account” pages to reflect the resource status changes.

  • •

    Delete the Age 18 RT diary and SSR remarks indicating the need for TA redevelopment.

  • •

    Follow the procedures in SI 01130.740 to develop ABLE account exclusions.

D. Development and documentation of TAs in the post-growth period (beginning January 1 of the calendar year in which the TA beneficiary attains age 18.)

While developing TA resources for months beginning January 1 of the calendar year in which the TA beneficiary attains age 18 and thereafter:

  • •

    Develop TA ownership, account value, and distributions, as applicable. Obtain evidence following normal resource verification policies in SI 01140.010.

  • •

    Develop for contributions to the TA. If the TA beneficiary alleges or evidence indicates contributions to a TA, determine whether the contributions are income or conversions of a resource and document the contributions according to normal policies (e.g., SI 00810.010, SI 01110.600).

  • •

    When an individual alleges resource values that preclude SSI eligibility, accept the allegation following SI 01140.010B.2.a.

  • •

    Count the value of TAs (i.e., the amount that the TA beneficiary can withdraw after any penalty for early withdrawal), unless the account can be excluded under another policy (e.g., an approved Plan to Achieve Self-Support, SI 00870.001).

    NOTE: 

    Penalties for early withdrawal for a given year are available on the IRS website, where they are referred to as "additional tax for early withdrawal." The penalty tax is the same for TAs and traditional IRAs.

  • •

    Record TAs (or update previously developed TAs) on an “Other Resources” page under the type “Trump Account (TA).” See MS 08113.032 for more information on the Other Resources page.

    NOTE: 

    Ensure the growth-period TA resource exclusion has been removed effective January 1 of the calendar year the TA beneficiary attains age 18.

  • •

    Store account statements or other evidence in the electronic folder using the Evidence Portal.

If the recipient or payee fails to provide information necessary for determining continuing eligibility, see SI 02301.235.

E. Examples of TA development

1. Young child qualifying for the pilot program contribution

In a 7/10/26 initial application for a disabled child born 10/1/25, the CS learns from the child’s mother that she made a TA election for the child when she filed her taxes, listing herself as the “responsible party” who would oversee the account. No contributions have been made, but she alleges the government is putting $1,000 into the account through the pilot program. The CS lists the TA on the “Other Resources” page, notes the mother as the account custodian in the description, and then posts the $1,000 alleged balance to the "Excluded Amount" field in July 2026 and continuing with the exclusion reason “TA.” The CS adds an RT diary to the record with a maturity date of 010142. The CS annotates in the SSR remarks field “RT-01/01/42 Age 17 TA/ABLE Rollover development.”

2. Special development during routine redetermination for a 16-year-old child

During a 5/1/27 redetermination for a disabled child born 4/3/2011, the CS learns the child’s father established a TA for the child during the 2026 tax season. The father alleges an account value around $1,500. He contributed $500 when he opened the account, and the child’s grandmother contributed $1,000 in December 2026. Because the child is 16 and special development applies, the CS informs the father that the child’s TA balance will become accessible, and therefore a countable resource for SSI purposes, on 1/1/29. The CS informs the father that the TA could be rolled over into an ABLE account between 1/1/2028 and 12/31/2028 and provides the link to the ABLE Spotlight for more information. The CS requests evidence of the TA and its value and requests that the father report if an ABLE rollover is pursued.

Before closing the redetermination event, the CS completes the “Other Resources/TA” page using information from a current TA account statement, listing account details in the “Description” field, and posting the current account value in the "Excluded Amount" field with the exclusion reason “TA.” The CS adds an RT diary with a maturity date of 120128 and annotates the SSR remarks field with “RT – 12/01/28 Age 18 develop TA/ABLE Rollover and remove TA exclusion effective 01/01/29.”

3. Post-Growth period TA development

The CS contacts the father from example 2 at the end of November 2028 to resolve the maturing Age 18 RT diary. During the review, the father reports that an ABLE account wasn't opened. The CS obtains an updated account statement for the TA, which shows a current balance of $1,720. The CS screens for resource exclusions, and, after finding none, advises the father that the funds would be a countable resource for the child beginning January 2029 and continuing. On the TA resource page, the CS calculates the early withdrawal penalty (10% of 1720=172; 1720-172=1548) and updates the verified resource value of $1,548 for December 2028. For January 2029 and continuing, the CS posts $1,548 as the alleged resource value, ensures the alleged account balance is removed in the "Excluded amount" field, and stores the TA account statement in Evidence Portal.

F. References

SI 00810.010 Relationship of Income to Resources

SI 01110.100: Distinction Between Assets and Resources

SI 01110.600: First-of-the-Month (FOM) Rule for Making Resource Determinations

SI 01130.740 Achieving a Better Life Experience (ABLE) Accounts

SI 01140.010 Resource Verification Requirements

SI 01150.007 Transfer of Resources by Spenddown


SI 01120 TN 105 - Identifying Resources - 7/09/2026