# PUBLIC COMMENT ON PROPOSED REGULATIONS: Trump Accounts Contribution Pilot Program

**Submitted by the Center for Federal Accountability (CFA)**  
**Document Number:** 2026-04534

## Executive Summary

The Center for Federal Accountability submits this draft comment to support timely public record participation while full model-backed legal analysis is queued. This draft identifies baseline accountability concerns and preserves key issues for agency consideration before the close of comments.

## Table of Authorities (to be finalized)

- Administrative Procedure Act (5 U.S.C. 551 et seq.)
- Agency enabling statute and implementing regulations (rule-specific citations to be finalized)

## Key Concerns

- The agency should clearly identify statutory authority for each material requirement in the proposal.
- The agency should provide transparent cost, burden, and implementation assumptions with reproducible methodology.
- The agency should address foreseeable operational risks and unintended consequences for regulated parties and the public.

## Preliminary Analysis

This preliminary draft is generated from the available Federal Register text excerpt below and is intended to preserve issues for the rulemaking record. A full model-backed CFA legal analysis can be substituted in a subsequent revision.

> Federal Register, Volume 91 Issue 45 (Monday, March 9, 2026) [Federal Register Volume 91, Number 45 (Monday, March 9, 2026)] [Proposed Rules] [Pages 11203-11212] From the Federal Register Online via the Government Publishing Office [ www.gpo.gov ] [FR Doc No: 2026-04534] ----------------------------------------------------------------------- DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 301 [REG-117002-25] RIN 1545-BS00 Trump Accounts Contribution Pilot Program AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. ----------------------------------------------------------------------- SUMMARY: This document contains proposed regulations relating to the Trump accounts contribution pilot program under which the Trump accounts of eligible children can receive $1,000 pilot program contributions. Eligible children must be U.S. citizens with valid Social Security numbers born in 2025 through 2028. The proposed regulations would provide guidance on making an election for the Trump account of an eligible child to receive a $1,000 pilot program contribution. The proposed regulations would affect eligible children and individuals who would make elections with respect to those children. DATES: Written or electronic comments and requests for a public hearing must be received by April 8, 2026. ADDRESSES: Commenters are strongly encouraged to submit public comments electronically via the Federal eRulemaking Portal at https://www.regulations.gov (indicate IRS and REG-117002-25) by following the online instructions for submitting comments. Requests for a public hearing must be submitted as prescribed in the ``Comments and Requests for a Public Hearing'' section. Once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn. The Department of the Treasury (Treasury Department) and the IRS will publish for public availability any comments submitted to the IRS's public docket. Send paper submissions to: CC:PA:01:PR (REG-117002-25), Room 5503, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Molly…

## CFA Recommendations

1. Publish a clear crosswalk from each proposed requirement to its statutory basis.
2. Expand and disclose the quantitative assumptions used in cost-benefit analysis.
3. Provide implementation alternatives and phase-in options to reduce compliance risk.
4. Extend or reopen comment if substantial updates are made after publication.

## CFA Contact

Center for Federal Accountability (CFA)  
8401 Mayland Dr # 7387  
Richmond, VA 23294  
policy@federalaccountability.com | https://www.federalaccountability.com/

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_Generated via cursor provider fallback at 2026-03-23T20:59:13.730545+00:00._