Staff in the U.S. Securities and Exchange Commission’s Divisions of Investment Management and Corporation Finance issued no-action positions addressing the federal securities law treatment of the U.S. Treasury’s Master Trust for automatically established Trump Accounts. Staff would not recommend enforcement under the Investment Company Act if the Master Trust relies on the exclusion for U.S. government instrumentalities. Staff also would not recommend action if interests issued to Auto Accounts are not registered under the Securities Act or, if treated as equity securities, under Section 12(g) of the Exchange Act. The positions reflect Treasury’s control over the Master Trust, including eligibility and contribution determinations, default investments, subtrust terms and investment directions. The Bank of New York Mellon serves as Treasury’s financial agent and trustee, with limited responsibilities and subject to Treasury oversight and replacement. The Master Trust will pool Auto Account assets and issue nontransferable book-entry interests representing each account’s proportionate stake in relevant subtrusts. The statement reflects staff views and was neither approved nor disapproved by the Commission.
U.S. Securities and Exchange Commission staff provides no-action positions for Trump Account Master Trust
U.S. Securities and Exchange Commission staff provided no-action positions for the Treasury-established Master Trust that will pool assets from automatically created Trump Accounts. The positions cover reliance on the Investment Company Act’s government instrumentality exclusion and the issuance of nontransferable trust interests without registration under the Securities Act or Section 12(g) of the Exchange Act.