Q: To what extent does an individual retirement account (IRA) fall within the definition of “covered account?”
A: An IRA is an “account” because it involves a continuing relationship established by a person with a financial institution or creditor to obtain a product or service for personal, family, household, or business purposes. Generally, IRAs will qualify as a “covered account” under the first part of the definition of a “covered account” (set out above under II.B.1) if offered by a financial institution or creditor. First, an IRA is offered primarily for personal, family, or household purposes. In addition, IRA accounts involve, and are designed to permit, multiple payments or transactions both during the accumulation phase when periodic contributions are made, and during the withdrawal phase when periodic withdrawals are made, as well as transactions (such as mutual fund investments) within the account itself.