ERIC asks Treasury to make BNY the Trump Account clearinghouse for employers

The ERISA Industry Committee wants the pipe built before employers start pouring money into it. In comments filed with the IRS and Treasury as the Trump Account rulemaking's comment period closed on Sept. 25, the trade group asked the agencies to make the Bank of New York — already the government's financial agent — a permanent central clearinghouse for employer contributions, with a way for employers to confirm an account is valid by its unique number before money moves.

Trump Accounts are tax-advantaged savings accounts for children, seeded with $1,000 from the federal government for every eligible child born between Jan. 1, 2025 and Dec. 31, 2028. Under Treasury's proposed rules published Aug. 11, Section 128 lets a worker receive up to $2,500 a year tax-free through a Trump Account contribution plan, a ceiling that has to absorb both the employer's money and the employee's own pre-tax deductions while after-tax family contributions can lift the combined total to $5,000 a year.

What ERIC wants beyond the clearinghouse — clear rules for correcting payroll errors, handling contributions that breach the $2,500 and $5,000 limits, and first-year relief — is unglamorous and necessary, and many of its member companies are exploring contributions. Andy Banducci, the group's senior vice president of retirement and compensation policy, frames the obstacle as verification: an employer cannot fund an account it cannot readily confirm, through a system that does not yet exist, under correction rules that make payroll mistakes hard to unwind.

The sequence echoes the rest of this year's retirement rollouts, where eligibility gets settled and delivery lags; August's proposed rules capped contributions and barred employers from steering money to a custodian, and Saver's Match guidance that month answered who qualifies for the federal match while leaving the money's route open.

ERIC is right to want the verification layer run as a utility rather than a vendor product, because splitting account confirmation across payroll providers and recordkeepers would leave an employer holding one integration per vendor with no way to check a number another provider controls, and a birth window that closes in 2028 puts a premium on getting employer money moving rather than letting the market sort out the connections. This publication has argued that whoever owns the workflow owns the plan relationship; here the ask is that the government's financial agent owns it, which for a program this young is the cheaper bet.

Permanence is the part that carries weight. A clearinghouse the agencies frame as temporary is a harder thing to wire into payroll than one they say will be there; employers weighing whether to offer contributions in the program's first year have to build against whatever answer comes back.