SEC Division of Trading and Markets no-action letter: Robinhood Financial LLC and Robinhood Securities, LLC

May 5, 2026
John S. Markle
Counsel for Robinhood Financial LLC and Robinhood Securities, LLC 250 Massachusetts Avenue, N.W. Washington, D.C. 20001 Re: Request for No-Action Relief from Form CRS Delivery Requirements for Certain Limited-Purpose Retirement Accounts (“Trump accounts”) Dear Mr. Markle, Based on the facts and circumstances set forth in your letter dated May 5, 2026 (“Letter”),1 the staff of the Division of Trading and Markets (“Division”) will not recommend enforcement action to the Securities and Exchange Commission (“Commission”) under rule 17a-14(c) of the Securities Exchange Act of 1934 (“Exchange Act”)2 if Robinhood Financial LLC and Robinhood Securities, LLC (collectively, “Robinhood”), in connection with Robinhood’s role as the sole broker-dealer and initial trustee, does not deliver Form CRS to parents, legal guardians or individuals authorized by the United States Department of the Treasury who open Trump accounts on behalf of eligible individuals. The Division staff’s position is limited to the period during which Robinhood serves as the sole broker-dealer and initial trustee for Trump accounts. The position of the Division staff is based strictly on the facts and circumstances stated in the Letter. Any different facts or circumstances from those set forth in the Letter might require a different response. Furthermore, this response expresses the Division staff’s position on enforcement action under rule 17a-14(c) only and does not purport to express any legal conclusions on the question presented. The Division staff expresses no view with respect to any other questions that the proposed activities 1 A copy of the Letter is attached. 2 17 CFR 240.17a-14(c).

2 discussed above may raise, including the applicability of any other federal or state laws or rules, or any self-regulatory organization rules. This position is subject to modification or revocation at any time.

Sincerely,
Emily Westerberg Russell
Chief Counsel
Division of Trading and Markets

250 Massachusetts Avenue, N.W.
Washington, D.C. 20001
Via Email
May 5, 2026
Ms. Emily Westerberg Russell
Chief Counsel
Division of Trading and Markets
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Request for No-Action Relief from Form CRS Delivery Requirements for Certain Limited-Purpose Retirement Accounts (“Trump accounts”) Dear Ms. Russell:
Robinhood Financial LLC (“RHF”) and Robinhood Securities, LLC (“RHS”) (collectively, “Robinhood”), 1 registered broker-dealers under the Securities Exchange Act of 1934 (the “Exchange Act”) and members of the Financial Industry Regulatory Authority, Inc. (“FINRA”), respectfully request that the staff of the Division of Trading and Markets (the “Staff”) confirm that it would not recommend enforcement action to the Securities and Exchange Commission (“SEC” or “Commission”) under Exchange Act Rule 17a-14(c) 2 if Robinhood does not deliver Form CRS to parents, legal guardians or individuals authorized by the Treasury (collectively, “Authorized Individuals”) who open Trump accounts on behalf of eligible individuals. This request is limited to the period during which Robinhood serves as the sole broker-dealer and initial trustee for Trump accounts. As described below, 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. 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. Moreover, these accounts cannot be transferred to another broker-dealer during the period in which Robinhood acts as the sole broker-dealer and initial trustee. In light of these characteristics, application of the Form CRS delivery requirement would not further the 1 RHF acts as introducing broker and RHS is the clearing broker and nonbank trustee for the Trump accounts. The United States Department of the Treasury (“Treasury”) has chosen Robinhood to act as sole broker-dealer and initial trustee for Trump accounts consistent with statutory criteria set forth in 26 U.S.C. § 530A(g). 2 See 17 C.F.R. § 240.17a-14; Form CRS Relationship Summary; Amendments to Form ADV, Rel. No. 34-86032, 84 Fed. Reg. 33,492 (July 12, 2019) (“Form CRS Adopting Release”).

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Commission’s stated objectives of enhancing retail investor understanding of brokerage relationships, conflicts of interest, competitive alternatives, or costs.
I. Background and Trump Account Structure
Section 70204 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as
the “One Big Beautiful Bill Act of 2025” or (“OBBBA”), added new sections 530A and 6434 to the Internal Revenue Code, which resulted in the creation of Trump accounts. Trump accounts are a special type of individual retirement account established by Authorized Individuals for the exclusive benefit of eligible individuals as defined in 26 U.S.C § 530A(b)(2). Earlier this year, trumpaccounts.gov announced it would begin accepting Authorized Individuals’ submission of IRS Form 4547 evidencing the intent to establish a Trump account for an eligible individual. Funding of the Trump accounts, including the $1,000 pilot program contribution for eligible individuals born after December 31, 2024, and before January 1, 2029, is expected to begin on July 4, 2026. 3 In addition to the pilot program, individuals, employers, and others also will be permitted to contribute up to a total of $5,000 per year, with employers’ contributions limited to $2,500 per year. Until the end of the “Growth Period” (the period that begins when a Trump account is established and ends on December 31 of the calendar year in which the account beneficiary 4 attains age 17), Trump accounts are subject to limitations:

• Restricted Investment Universe: Trump accounts may only transact in certain
  investments. Section 530A(b)(3) limits “eligible investment” to any mutual fund or exchange traded fund which: (i) tracks the return of a qualified index; (ii) does not use leverage; (iii) does not have annual fees and expenses of more than 0.1 percent of the balance of the investment of the fund; and (iv) meets such other criteria as the Secretary of the Treasury determines appropriate. 5
• No Fees or Compensation: Robinhood will not receive commissions, account-level
  fees, or other compensation from the Trump accounts.
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  3 All children under the age of eighteen meeting the requirements of eligible individuals under 26 U.S.C. § 530A may have a Trump account established for them.

4 After a Trump account has been opened for an eligible individual, the individual is referred to as the account beneficiary. 26 U.S.C. § 530A(b)(4). 5 26 U.S.C. § 530A(b)(3)(A). 6 Financial Agents of the Federal Government are authorized “to accept deposits of public money and to perform other services as may be required of them.” 31 C.F.R. § 202.1. Treasury has chosen a Financial Agent to receive funding from Treasury for the establishment of Trump accounts and Robinhood has been chosen to act as the sole broker-dealer and initial trustee for the Trump accounts. The Financial Agent contracts with Robinhood to provide services to the Trump accounts. As contained in its agreement between Robinhood and the Financial Agent, Robinhood will not be permitted to collect any fees directly or indirectly from the Trump accounts. Rather, Robinhood will be compensated in accordance with the agreements between the Financial Agent and Treasury and between the Financial Agent and Robinhood Markets, Inc., RHF’s and RHS’ corporate parent.

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• Restrictions on Distributions: Treasury regulations dictate that account
  distributions are not permitted during the Growth Period of Trump accounts. 7
• No Cross-Marketing of Other Services: Robinhood will not be permitted to offer or
  market additional products or services to Trump accounts while acting as the initial trustee for the Trump accounts. 8 Consistent with the above requirements, Trump accounts are intended to function as standardized, passive investment vehicles designed solely to facilitate long-term exposure to broad-based market indices. 9
  II. Regulatory Framework and Purpose of Form CRS
  SEC registered broker-dealers that offer services to retail investors 10 are subject to Form CRS requirements, including Form CRS delivery requirements. Rule 17a-14(c) under the Exchange Act requires broker-dealers to deliver Form CRS to retail investors before or at the earliest of: (i) a recommendation of an account type, a securities transaction, or an investment strategy involving securities; (ii) placing an order for the retail investor; or (iii) the opening of a brokerage account for the retail investor. 11

In addition, a broker-dealer must deliver a current Form CRS to each retail investor within 30 days, upon request. Form CRS requires broker-dealers to provide concise disclosures regarding:

• the types of services the firm offers;
• the fees, costs, conflicts of interest, and required standard of conduct associated with
  those services;
  7 26 U.S.C. § 530A(d)(1). Final regulations have not been issued and may include additional or different periods of restricted activity until the account beneficiary attains age 18. 8 The limitation on cross-marketing is contained in the agreement between the Financial Agent and Robinhood. 9 During the calendar year the account beneficiary reaches the age of eighteen, by contract or by action of the account beneficiary, the Trump account may automatically be converted to a traditional IRA for the account beneficiary that is not a Trump account. Trump Accounts Contribution Pilot Program, 91 Fed. Reg. 11203, 11204 (Mar. 9, 2026) (“After the period beginning when a Trump account is established and ending on December 31 of the calendar year in which a Trump account beneficiary attains age 17 (growth period), most of the special rules no longer apply and the rules under section 408 governing traditional IRAs generally apply.”) 10 Rule 17a-14(e)(2) defines “retail investor” as “a natural person, or the legal representative of such natural person, who seeks to receive or receives services primarily for personal, family or household purposes.” 11 In addition, pursuant to Rule 17a-14(c)(2) broker-dealers must deliver Form CRS to existing customers who are retail investors before or at the time the broker-dealer: (i) opens a new account that is different from the retail investor's existing account(s); (ii) recommends that the retail investor roll over assets from a retirement account into a new or existing account or investment; or (iii) recommends or provides a new brokerage service or investment that does not necessarily involve the opening of a new account and would not be held in an existing account.

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• whether the firm and its financial professionals have reportable legal or disciplinary
  history; and
• how to get more information about the firm. 12
  In adopting Form CRS, the Commission emphasized that the relationship summary is intended to assist retail investors in “understanding and comparing the types of services offered by broker-dealers and investment advisers”13 and to help retail investors “make a more informed choice among the types of firms and services available to them.”14 The Commission further explained that Form CRS is designed to address “information asymmetries between firms and retail investors” and highlight key differences in services, fees, and conflicts. 15

III. Basis for No-Action Relief
To administer the Trump accounts, Robinhood will be required to open a brokerage account for retail investors. Robinhood acknowledges that Rule 17a-14(c) generally requires delivery of Form CRS upon the opening of a retail brokerage account. Robinhood respectfully submits that Form CRS delivery requirements should not apply in this discrete and narrowly defined context, where Robinhood has been appointed by the Treasury to serve as the sole broker-dealer and initial trustee for all Trump accounts. A primary purpose of Form CRS is to provide retail investors with important information about the fees they will pay and conflicts of interest, in order to help investors decide which firm they will retain to service their accounts. 16 As described below, Authorized Individuals will not choose among competing firms, account types, or service models, will not pay account-level fees to Robinhood, and will not be subject to conflicts arising from recommendations, compensation structures, or product selection. Form CRS delivery in this context would not further, and could potentially obscure, the purpose of Form CRS by implying the existence of fees, conflicts, or service alternatives where none, in fact, exist. A. Robinhood is the Sole Broker-dealer and Initial Trustee The Commission’s rationale for Form CRS presupposes that the retail investor will be able to choose which firm it would like to service its account. As the SEC noted in the Form CRS Adopting Release:
Research continues to show that retail investors are confused about the services, fees, conflicts of interest, and the required standard of conduct for particular firms, and the differences between broker-dealers and investment advisers. We are adopting a new set of disclosure requirements designed to reduce retail investor confusion in the marketplace for brokerage and investment advisory services and to assist retail investors with the process of deciding whether to engage, or to continue to 12 See Form CRS Adopting Release, 84 Fed. Reg. at 33,516–40. 13 Id. at 33,497. 14 Id. at 33,628. 15 Id. at 33,497–98. 16 Id. at 33,493.

5 engage, a particular firm or financial professional and whether to establish, or to continue to maintain, an investment advisory or brokerage relationship. 17 Accordingly, Form CRS is intended to facilitate the investor’s decision-making by allowing the investor to evaluate and compare:

• the difference between brokerage and advisory relationships;
• differing fee structures within a firm and across different firms; and
• varying conflicts of interest within a firm and across different firms.
  These considerations currently are not present in Trump accounts. First, Robinhood was chosen as the sole broker-dealer and initial trustee to offer and custody the Trump accounts. Authorized Individuals do not select Robinhood from among competing providers but instead elect to participate in a government-created program for which Robinhood serves as the designated provider as a subcontractor of the Treasury. Second, Authorized Individuals are not presented with a menu of services or products, nor are they making comparative judgments among alternatives offered by Robinhood or any other firm. As such, Form CRS would not provide helpful or actionable disclosures. 18 In this limited context, receiving a Form CRS from Robinhood could create confusion by suggesting that the investors may choose among different account types or services when no such choice exists. 19

B. Mitigation of Material Conflicts of Interest Among other things Form CRS is intended to inform retail investors about certain conflicts of interest. 20 The way Trump accounts initially are structured mitigates material conflicts of interest associated with recommendations, compensation or product selection:

• no proprietary or affiliated products are offered;
• compensation does not vary based on investment selection;
• no recommendations are made; and
• no cross-selling or ancillary revenue opportunities exist.
  Where, as here, conflicts are materially limited or absent, Form CRS disclosures regarding such conflicts would not provide meaningful or decision-useful information. 17 Id. (emphasis added). 18 In the limited circumstances here – where the account structure eliminates the core elements Form CRS is designed to address – application of the rule would not further its intended objectives. 19 Requiring delivery of Form CRS in this context could result in disclosures that imply the existence of fees, conflicts, or service alternatives where none exist, and therefore could be misleading to Authorized Individuals. The Commission has cautioned against including information pertaining to other services that would obscure or impede understanding of the information that must be disclosed in Form CRS. See Form CRS Adopting Release, 84 Fed. Reg. at 33,513. 20 See Form CRS Adopting Release, 84 Fed. Reg. at 33,493.

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C. Absence of Fees or Costs
Form CRS is intended, in part, to highlight the costs associated with brokerage services. 21 Trump accounts involve no account-level fees or commissions because Robinhood will not be permitted to collect fees directly or indirectly from Trump accounts. D. Consistency with Prior Staff Positions Finally, the Staff has, in various contexts, provided relief or interpretive guidance where the application of a general disclosure regime would not serve its intended purpose due to the limited or specialized nature of the brokerage relationship. Most relevant here, in 2020, the Staff provided no-action relief from Form CRS delivery requirements where certain broker-dealers proposed to open accounts and provide other brokerage services to retail investors who operated as institutional family offices and met certain other conditions as described in that letter. 22 The request for relief explained that the institutional family offices had a unique client relationship with the broker-dealers that was not a typical “retail investor”/broker-dealer relationship. 23 And, because of that unique relationship, they would not benefit from Form CRS disclosures. 24 The same principle applies here. Trump accounts represent a statutorily constrained and programmatic account structure that lacks the features of a typical retail brokerage relationship to which Form CRS is directed. Granting relief here would be consistent with this principles-based approach and limited to the specific facts and circumstances described herein, including the designation of Robinhood as the sole broker-dealer and initial trustee for the Trump accounts in the absence of fees, mitigation of conflicts of interest, and lack of investor choice.
IV. Alternative Investor Protection Measures
In lieu of Form CRS, Robinhood represents that it will provide disclosures tailored to the specific characteristics of Trump accounts, including:

• clear, prominent explanations of the account’s limited investment scope;
• plain-English descriptions of the absence of account-level fees, advice, and
  additional services;
• ongoing transparency regarding account functionality; and
• a link to FINRA’s Broker Check website that permits customers to access information
  about Robinhood, including its disciplinary history.
  These disclosures are designed to provide information that is directly relevant to the Trump account structure, rather than the generalized disclosures contemplated by Form CRS. In addition, the individual establishing the account will be required to affirmatively acknowledge the 21 Id. at 33,524. 22 SEC Staff Letter to Stephanie Nicolas, WilmerHale (on behalf of SIFMA) (Dec. 23, 2020). 23 Letter from Stephanie Nicolas, WilmerHale (on behalf of SIFMA) to Emily Westerberg Russell, Chief Counsel, Division of Trading and Markets, SEC (Dec. 23, 2020).

24 Id.

7 limitations on Eligible Investments and other key account restrictions during the account opening process.
V. Request for No-Action Relief
For the reasons described above, Robinhood respectfully requests that the Staff not recommend enforcement action under Rule 17a-14(c) if Robinhood does not deliver Form CRS in connection with its role as the sole broker-dealer and initial trustee for Trump accounts, subject to the representations set forth herein.
VI. Conclusion
Trump accounts’ unique structure and limitations address or effectively mitigate the core considerations—fees, conflicts, service variability, and recommendations—that Form CRS is designed to address. In this limited context, requiring the delivery of Form CRS would not advance investor protection and could introduce confusion or misleading inferences. The requested relief is therefore consistent with the Commission’s regulatory framework for Form CRS and prior Staff positions recognizing the need to tailor disclosure obligations to the nature of the investor relationship. Respectfully submitted, John S. Markle Counsel for Robinhood Financial LLC and Robinhood Securities, LLC