Securities Regulation Daily Wrap Up, BROKER-DEALERS—SEC staff give Robinhood the go-ahead to manage initial roll-out of Trump Accounts, (May 6, 2026)

By Mark S. Nelson, J.D.

Robinhood said the no-action relief was needed to ease its burden to provide relationship summaries when such disclosures did not fit the goal of the federal government’s retirement savings program.

The SEC granted no-action relief to Robinhood Financial LLC for the purpose of Robinhood’s administration of retirement savings accounts known as Trump Accounts that will soon be available to certain eligible individuals under a provision contained in the One Big Beautiful Bill Act of 2025. The relief is narrowly drafted to remove Robinhood’s obligation to provide relationship summaries on Form CRS to investors in the accounts. The SEC’s Division of Trading and Markets granted the no-action relief, but limited its scope to the period when Robinhood acts as the sole broker-dealer and initial trustee for Trump Accounts.

SEC Chair Paul S. Atkins said the no-action relief granted by the agency to Robinhood would ensure that key investor protections remain in place for Trump Account investors. “Trump Accounts present a historic opportunity to change the course of the lives of the next generation by helping Americans save and invest for the future,” said Atkins in a brief statement announcing the no-action relief.

The OBBBA amended the Internal Revenue Code to create Trump Accounts, a type of individual retirement account for individuals born after December 31, 2024, and before January 1, 2029, who might not otherwise be eligible to participate in other types of retirement savings accounts. The program includes a federal government $1,000 pilot program contribution and would allow eligible individuals and employers to contribute $5,000 per year (employers’ contributions would be limited to $2,500 per year). The program also limits investment choices, bars Robinhood from receiving compensation for its related services, limits distributions during the “growth period,” and bars Robinhood from engaging in related cross-marketing of its services and products. The program is set to begin on July 4, 2026.

Broker-dealers and investment advisers were required to issue relationship summaries on Form CRS as an adjunct to the rulemaking that resulted in the Commission adopting Regulation Best Interest. The Commission at the time said investors had a poor understanding of the differences between broker-dealers and investment advisers. As a result, the Form CRS relationship summary would provide disclosures about a broker-dealer’s or investment adviser’s relationships and services offered to retail investors, fees and costs that retail investors pay, detail conflicts of interest and standards of conduct, and disclose the firm’s disciplinary history. The Investment Advisers Act rules and Form

ADV contains the Form CRS requirement for investment advisers, and Exchange Act Rule 17a-14 contains the same requirement for broker-dealers.

Rule 17a-14(c) obligates broker-dealers to do five things regarding Form CRS: (1) deliver a current Form CRS to each of the broker-dealer's retail investors at the prescribed time; (2) deliver a current Form CRS to each retail investor who is an existing customer at the prescribed time; (3) post the broker-dealer's current Form CRS prominently on its public website such that it is easily accessible to retail investors; (4) communicate any changes made to Form CRS to each retail investor who is an existing customer within a prescribed time; and (5) deliver a current Form CRS to each retail investor within 30 days upon request.

Robinhood’s theory underlying its request for no-action relief from Rule 17a-14(c) emphasized the goals of the Form CRS requirement and how they may not apply in the context of Trump Accounts.

“Rule 17a-14(c) should not apply to Trump accounts because they are subject to statutory limitations that materially limit account features in a way that, at least initially, do not create the kind of relationship with retail investors that Form CRS was designed to address,” explained Robinhood in its no-action request letter. “Trump accounts are structured as non-advisory, non-discretionary accounts limited to investments in broad-based index funds, with no associated account-level fees, compensation, or material conflicts of interest of the type Form CRS is designed to address.”

Robinhood also noted that Trump accounts are not transferrable to other broker-dealers during the period Robinhood remains sole broker-dealer and initial trustee for Trump accounts.

Companies: Robinhood Financial LLC; Robinhood Securities, LLC

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