1. Introduction: What is Form 15250?

IRS Form 15250, officially titled Nonbank Trustee/Custodian Status Notification, is a specialized regulatory compliance form published by the Internal Revenue Service (IRS). It is governed by Employee Plans within the IRS Tax Exempt and Government Entities (TE/GE) Division pursuant to Treasury Regulation Section 1.408-2(e).

This form is not a tax return filed by individual taxpayers or general commercial businesses. Instead, it is an administrative notification document used by nonbank entities—such as specialized trust companies, brokerage firms, mutual fund managers, and financial custodians—that have been officially approved by the IRS to serve as trustees or custodians of tax-advantaged retirement and savings accounts. Form 15250 allows these organizations to notify the IRS of their ongoing operational status, report changes in corporate name or address, or formally relinquish their approved custodial status.

2. Purpose of the Form: Why Does Form 15250 Exist?

Under Internal Revenue Code Section 408(a)(2), the trustee or custodian of an Individual Retirement Account (IRA) must generally be a bank, credit union, or federally insured financial institution. However, the statute permits nonbank entities to act as trustees or custodians if they prove to the satisfaction of the IRS that they possess the fiduciary capability, financial responsibility, and operational competence required by Treasury Regulation Section 1.408-2(e).

Once approved, nonbank trustees and custodians hold fiduciary custody over billions of dollars in Traditional IRAs, Roth IRAs, Health Savings Accounts (HSAs), Coverdell Education Savings Accounts (ESAs), and ABLE accounts. Form 15250 exists to maintain regulatory oversight over these approved institutions:

Maintaining the Public Registry: The IRS publishes an official cumulative list of approved nonbank trustees and custodians. Form 15250 ensures that this public directory reflects only active, solvent, and compliant organizations.
Reporting Corporate Restructuring: When a nonbank custodian changes its legal name, relocates its primary business office, undergoes a merger, or changes its Employer Identification Number (EIN), Form 15250 updates IRS records to preserve the entity’s active approval status.
Orderly Relinquishment of Authority: If an organization decides to exit the custodial business or liquidate, Form 15250 provides a formal mechanism to surrender its notice of approval, ensuring account holders can be transferred to a qualified successor trustee.

3. Who Needs to File This Form?

Form 15250 is completed exclusively by financial entities that have already received official IRS approval to act as nonbank trustees or custodians. You need to file Form 15250 if your organization:

Was previously issued a formal IRS Notice of Approval to act as a nonbank trustee or custodian under Treasury Regulation Section 1.408-2(e).
Continues to operate as an active nonbank trustee or custodian and needs to reconfirm active status in response to an IRS compliance inquiry.
Has undergone a legal corporate name change, physical address change, or Employer Identification Number (EIN) change since receiving IRS approval.
Wishes to voluntarily surrender or relinquish its IRS approval notice.
Is no longer in existence due to corporate merger, acquisition, liquidation, or dissolution.

4. Who Is Exempt / Not Required to File?

The vast majority of financial institutions and taxpayers never need to handle Form 15250:

Federally Insured Banks and Credit Unions: Commercial banks, savings associations, and credit unions are automatically authorized by statute under Internal Revenue Code Section 408(n) to serve as IRA custodians and do not require nonbank approval or status notifications.
Entities Applying for Initial Approval: If an organization is seeking nonbank trustee status for the first time, do not file Form 15250. You must submit a comprehensive written application and fee under Treasury Regulation Section 1.408-2(e) and annual IRS revenue procedures.
Individual Taxpayers and Account Holders: Everyday citizens holding self-directed IRAs, HSAs, or retirement accounts never file this form.
Introducing Brokers and Advisors: Financial advisors and broker-dealers that custody client retirement assets through an outside clearing bank or approved trust company do not hold direct nonbank trustee status and are exempt.

5. When to File: Deadlines and Frequency

Form 15250 is an event-based notification rather than an annual recurring filing. It should be submitted as soon as a qualifying corporate event occurs.

An organization must file Form 15250 promptly whenever it changes its legal name, relocates its corporate headquarters, changes its EIN, or decides to surrender its custodial authority. Additionally, the IRS periodically surveys approved nonbank trustees to clean up its master directory; when an organization receives an official status request letter from the IRS Employee Plans division, Form 15250 must be returned within the specific response deadline indicated in the notice (typically 30 calendar days).

6. Where and How to File

Form 15250 is a formal regulatory document that cannot be submitted through standard electronic payroll or tax return software. Organizations must deliver the document directly to the IRS Employee Plans division:

Paper Submission: Complete the paper Form 15250, obtain an original signature from an authorized corporate officer, and attach supporting legal documentation (such as amended articles of incorporation or merger certificates).
Mailing Address: Mail the completed notification package to the designated IRS address as per instructions for the Nonbank Trustee Program (typically IRS Employee Plans, TE/GE Division, in Washington, DC, or Cincinnati, Ohio).
Certified Delivery Recommended: Always mail Form 15250 via certified mail with return receipt requested or an approved private delivery service to maintain verified tracking of your regulatory submission.
Retain Legal Copies: Keep an exact copy of the signed form and all attachments in your corporate compliance archives.

7. Step-by-Step Instructions to Fill Form 15250

Form 15250 is a concise, single-page regulatory form. It captures baseline corporate details, your current operational status, and any corporate changes that have occurred since your original approval letter was issued. The table below outlines each section of the form.

Section	Item Name	Required Information & Standards
Part 1	Organization Details	Current legal name, trade name (DBA), Employer Identification Number (EIN), address, and phone number.
Part 2	Current Status	Checkbox selecting: (1) Continuing in business, (2) Relinquishing approval, or (3) No longer in existence.
Part 3	Corporate Changes	Checkboxes and detail fields for Name Changes, Address Changes, or EIN Changes with effective dates.
Part 4	Execution & Signature	Original signature of an authorized corporate officer, printed name, corporate title, date, and phone number.

Part 1: Organization Identification

Enter your organization’s complete legal name exactly as registered with corporate authorities. If your business operates under a trade name, “doing business as” (DBA) name, or commercial division, enter that information accurately. Provide your current nine-digit Employer Identification Number (EIN), primary corporate business address, and daytime telephone number.

Part 2: Indicating Current Operational Status

You must review your business operations and check the single box that accurately reflects your organizational status:

Continuing in Business: Check this box if your organization remains actively in business as an approved nonbank trustee or custodian under Treasury Regulation Section 1.408-2(e).
Relinquishing Notice of Approval: Check this box if your organization is voluntarily giving up its nonbank trustee/custodian status. You must confirm that all custodial retirement accounts have been transferred to an authorized successor custodian.
No Longer in Existence: Check this box if the entity has legally dissolved, liquidated, or been absorbed into another corporate entity through a merger.

Part 3: Changes in Entity Information Since Approval

If your organization checked “Continuing in Business” but has undergone structural updates since its original IRS approval letter, complete the change fields:

Name Change: Check the box, enter the previous legal name, the new legal name, and attach a copy of the amended articles of incorporation certified by the state of incorporation.
Address Change: Check the box and provide the previous corporate address and the new physical headquarters address.
EIN Change: Check the box, provide the previous EIN and the newly assigned EIN, and explain the tax restructuring that necessitated the new number.

Part 4: Officer Signature and Attestation

Form 15250 must be signed and dated by an authorized corporate officer (such as the President, Chief Executive Officer, Chief Financial Officer, Managing Member, or General Counsel). The officer must print their full legal name, official title, date, and contact telephone number. An unauthorized employee or external agent lacking corporate authority cannot sign.

8. Required Documents and Information Needed Before Filling

Before completing Form 15250, assemble the following corporate and regulatory records:

A copy of your original IRS Notice of Approval granting nonbank trustee or custodian status under Treasury Regulation Section 1.408-2(e).
Your organization’s active Employer Identification Number (EIN).
Certified copies of state corporate filings (such as Certificates of Amendment, Certificates of Merger, or Articles of Dissolution) if reporting a name change or corporate termination.
Written confirmation of successor trustee transfer agreements if relinquishing custodial authority.
Documentation substantiating the signing officer’s legal authority to bind the entity.

9. Common Mistakes to Avoid

Errors on Form 15250 can cause an approved entity to be mistakenly removed from the IRS public trustee registry. Watch out for these frequent mistakes:

Using Form 15250 to Apply for Approval: Form 15250 is strictly for existing approved entities. It cannot be used to apply for initial nonbank trustee status; initial applications require a comprehensive legal demonstration and user fee.
Failing to Report Name Changes: If your company rebrands or changes its corporate name without filing Form 15250, your old name will remain on the IRS public list. Clients and financial institutions may question whether your new entity is legally authorized to custody IRAs.
Relinquishing Status Without Transferring Accounts: You cannot simply walk away from custodial responsibilities. Before checking “Relinquishing” or “No longer in existence,” you must ensure all client accounts have been transferred to an authorized bank or nonbank custodian.
Unauthorized Signatures: Submitting Form 15250 signed by a low-level manager or outside consultant will cause the IRS to reject the notification as unverified.
Omitting Supporting State Documents: Failing to attach certified state filing amendments when reporting a legal name change will delay IRS recognition.

10. Penalties for Non-Filing or Errors

Because Form 15250 is an administrative regulatory notice, there are no direct tax fines for failing to file it. However, the legal, financial, and commercial consequences for noncompliance are catastrophic:

Revocation of Nonbank Trustee Status: Under Treasury Regulation Section 1.408-2(e)(7), the IRS may initiate formal proceedings to revoke an entity’s notice of approval if the organization fails to respond to status inquiries or no longer satisfies regulatory standards.
Disqualification of Client Retirement Accounts: If an organization acts as an IRA trustee without valid IRS approval, all customer IRAs lose their tax-exempt status. The accounts are deemed distributed, triggering income taxes and 10% early withdrawal penalties for innocent account holders.
Removal from the Public Approved Directory: The IRS will remove defunct, unverified, or noncompliant entities from its published list of approved nonbank custodians, causing broker-dealers, clearinghouses, and institutional investors to terminate commercial partnerships.
Perjury and False Statement Liabilities: Falsifying corporate status, concealing mergers, or submitting fraudulent notifications is a federal crime punishable under 18 U.S.C. Section 1001.

11. Related Forms or Schedules

Form 15250 operates within a specialized collection of retirement plan, custodial, and information reporting forms:

Treasury Regulation Section 1.408-2(e): The governing federal regulation outlining requirements for nonbank trustees and custodians.
Form 5498: IRA Contribution Information (filed annually by approved custodians to report contributions and fair market values).
Form 1099-R: Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
Form 5498-SA: HSA, Archer MSA, or Medicare Advantage MSA Information.
Form 5498-ESA: Coverdell ESA Contribution Information.
Form 8822-B: Change of Address or Responsible Party – Business.

12. Frequently Asked Questions (FAQs)

1. What is an IRS “nonbank trustee” or “nonbank custodian”?

A nonbank trustee or custodian is an entity other than a federally insured bank (such as a private trust company, brokerage firm, or financial services corporation) that has received formal written approval from the IRS under Treasury Regulation Section 1.408-2(e) to hold custody of retirement and tax-advantaged accounts.

2. Can a company use Form 15250 to become an approved nonbank trustee?

No. Form 15250 is only used by entities that have already been approved by the IRS. To become an approved nonbank trustee, an organization must submit a formal written application demonstrating fiduciary ability, net worth, and administrative fitness, along with the required user fee.

3. What types of accounts can an approved nonbank trustee administer?

Depending on the scope of their original approval letter, nonbank trustees can administer Traditional IRAs, Roth IRAs, SEP-IRAs, SIMPLE IRAs, Health Savings Accounts (HSAs), Archer MSAs, Coverdell Education Savings Accounts (ESAs), and ABLE accounts.

4. What happens to customer accounts if an entity relinquishes its approval?

Before relinquishing approval, the nonbank trustee must notify all account owners and arrange for their accounts to be transferred to a qualified successor custodian (such as an FDIC-insured bank or another approved nonbank trustee) to ensure the accounts maintain continuous tax-qualified status.

5. Why does the IRS maintain a public list of approved nonbank trustees?

The IRS publishes the list so that consumers, financial advisors, and tax professionals can verify that an institution holding self-directed retirement assets is legally authorized by the federal government to serve as an IRA custodian.

6. Can Form 15250 be filed electronically?

No. Form 15250 must be prepared as a physical paper document, signed by an authorized corporate officer, and mailed directly to the IRS Employee Plans division at the designated address as per instructions.

13. Conclusion: Key Takeaways

IRS Form 15250 is an essential regulatory bridge that ensures the integrity of the nonbank custodial industry. By submitting this status notification, approved trust companies and financial custodians keep the IRS informed of their ongoing operations, document corporate name and address changes, and ensure their names remain on the official public directory of authorized fiduciaries.

Because failing to report corporate changes or maintaining custodial authority without proper standing can jeopardize the tax-qualified status of customer retirement accounts, nonbank fiduciaries should review their IRS approval status regularly, complete Form 15250 promptly when corporate changes occur, and consult with experienced ERISA and employee benefits legal counsel when managing nonbank trustee compliance.

IRS Form 15250 Guide: Nonbank Trustee Status Notification