The IRS maintains a list of entities approved, under Treasury Regulation Section 1.408-2(e), to serve as nonbank trustees or custodians.
List and application updates
We will frequently update this list as other nonbank trustees or custodians are added or removed. Entities will be removed from the list after their withdrawal or revocation has become final.
An approved nonbank trustee or custodian must notify the IRS in writing of any change in entity name, address or any other change that affects the continuing accuracy of any representation made in the application, as required by Treasury Regulation Section 1.408-2(e)(6)(v).
Additionally, an approved nonbank trustee or custodian should notify the IRS in writing, if the trustee or custodian:
- was incorrectly excluded from the list of approved nonbank trustees or custodians,
- is on the list but is no longer acting as a nonbank trustee or custodian, or
- needs to request any corrections.
Submit your written notification to:
Internal Revenue Service
SE:T:EP:RA:T1, Room 6213
1111 Constitution Ave., N.W.
Washington, DC 20224
Background
Nonbank trustees or nonbank custodians (NBT) are described under Treasury Regulation Section 1.408-2(e). An entity that is not a bank (or an insurance company in the case of Archer Medical Savings Accounts and health savings accounts) can request to be a nonbank trustee/custodian by applying in writing and demonstrating that certain requirements will be met in order to handle any of the following fiduciary accounts:
- Archer medical savings account (MSA)
- Health savings account
- Qualified retirement plan custodial account
- 403(b)(7) Custodial account
- Individual retirement arrangement (IRA)
- Roth IRA
- Deferred compensation plan of state & local government custodial accounts
- Coverdell education savings account
If the requirements described in Treasury Regulation Sections 1.408-2(e)(2) - (e)(5)(viii)(F) are met, the NBT applicant will receive a written notice of approval.