Writing in response to Treasury’s request for comment on forthcoming regulations for Section 530A Trump Accounts, Urban Institute experts highlight evidence that several elements of the program risk limiting participation among low- and moderate-income children. Drawing on decades of research on family financial well‑being, early wealth building, and tax administration, the authors raise concerns that current enrollment rules, trustee standards, and outreach plans may reduce access for low-income families, immigrant households, and children not claimed on tax returns. As a result, many eligible children could miss out on seed contributions and long‑term savings opportunities, weakening the program’s potential to build early wealth and advance economic mobility. The comments recommend a shift from opt‑in to automatic enrollment, stronger consumer‑protection requirements for trustees, transparent geographic targeting criteria, and robust, multilingual outreach strategies—all designed to increase participation, reduce administrative burdens, and ensure the program fulfills its goal of broad, equitable access to long‑term savings for children nationwide.