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Third Party Pooled Special Needs Trust (PSNT)

A Third-Party PSNT is established by a parent, relative, or friend of the beneficiary,

and can be coordinated with an estate plan, insurance policy, or gift.

Third Party Special Needs Trust:

Joining Documentation

Third Party Special Needs Trust: A family is walking down a street holding hands in front of a house.

Real Estate

We are thrilled to be able to offer our clients’ families and loved ones the opportunity to transfer a home for the Beneficiary into a third-party sub-account. We know this is such an important part of estate planning and providing for the Beneficiary’s future—a stable and familiar home.


Our New Client Team is ready to help you explore how this new option can be incorporated into your estate plan. We are also accepting homes as part of transfers or decanting from existing special needs trusts.


Please click the button below to learn about our real estate program and guidelines.

Real Estate Guidelines

What is a Third-Party

Pooled Special Needs Trust?

In this insightful video, discover the remarkable benefits of our Third-Party Pooled Special Needs Trust. Join our Counsel & Director of Client Services, Ben Tiefenback, as he delves into the details and advantages of this valuable resource.

Funding the Sub-account

The most common way trusts are funded is through the Grantor’s will, estate plan, life insurance policy, or employee benefit. The trust can also be funded by a gift, bequest, or inheritance. CCT accepts cash assets for deposit into the trust; no real estate or non-cash assets are accepted. Once funded, the trust is irrevocable.


Once the Grantor completes the Joinder Agreement and other forms, the trust is set up and waiting to be funded. There is no expectation that the account be funded immediately. The account is available to receive funds (cash/check) from any source and at any time. When appropriate it is helpful to notify family members and others about the Beneficiary’s sub-account and that funds be directed to the trust with CCT and not given or left directly to the individual (see sample letter).

Third Party Special Needs Trust: A little girl is carrying an older woman on her back.

How Funds in the Trust Can Be Used

The funds can be used to pay for expenses that will enhance the quality of life for the Beneficiary. Disbursements can be requested from the trust by a Primary or Secondary Advocate. Bills are paid by check to vendors or reimbursed to the Advocate or in certain circumstances a credit card is made available and funded by the Beneficiary’s sub-account.


For more information, see our Disbursement Information Manual.


Disbursement Information Manual

  • Disbursement requests are reviewed and approved based on the following criteria:

    • Is the request in the best interest of the Beneficiary?  
    • Is the request related to the health, education, maintenance and support of the Beneficiary?  
    • Are there adequate funds in the trust to cover the request?  
    • Is the request prudent?  
    • Was supporting documentation provided?
    • Is the Beneficiary a minor?  

  • Examples include, but are not limited to:

    • Medical and Dental Services not covered by insurance
    • Assistive Technology
    • Eyeglasses, Hearing Aids, and Prosthetic Devices
    • Pre-paid Burial Expenses
    • Computer and Internet Services
    • Education Expenses
    • Caregiver Expenses
    • Home Modifications
    • Clothing and Furniture

Additional Third-Party Resources

Third-Party Grantor Vision

The Grantor Vision and Information Form is an opportunity for the grantor to share their vision for how they wish for the trust to be used and to provide additional information about the beneficiary.

Third-Party Remainder Policy

The Remainder Policy explains what happens to funds remaining in the sub-account upon the death of the beneficiary.

CCT Trust IPS

The Investment Policy Statement (IPS) is carefully crafted and reviewed regularly by the CCT Board of Director’s Finance and Investment Committee.

Important Definitions

  • Pooled Trust

    A pooled trust refers to a unique trust structure when there is one Master Trust Agreement but multiple beneficiaries. The beneficiaries each have their own sub-account that is set up by completing the  Joinder Agreement, the legal document to join.  The funds in the sub-accounts are pooled for investment purposes. The Beneficiary and their advocate(s) have access to financial information through the CCT secure online portal, mobile app, and by mail upon request. 

  • Sub-Account

    A sub-account refers to the account holding funds for an individual Beneficiary.  Funds deposited into this sub-account are used solely for that Beneficiary.  The sub-account is governed by the terms of the CCT First-Party Pooled Special Needs Trust Master Trust Agreement and the completed Joinder Agreement, which states what will happen to any remaining funds if the Beneficiary passes away. 

  • Joinder Agreement

    The Joinder Agreement, our legal document to join the pooled trust, establishes the sub-account for the Beneficiary and gives essential information about the Beneficiary and the sub-account. CCT has a sample Joinder Agreement that is helpful when completing a new Joinder Agreement. 

Additional Definitions

Have questions?

If you have any questions about the process, please don’t hesitate to call our office at 804-740-6930 or email us at contact@trustCCT.org. Our staff is available to answer your questions Monday through Friday from 9:00 am to 5:00 pm ET.


Mailing Address:

Commonwealth Community Trust
P.O. Box 29408
Richmond, VA 23242-0408


Third Party Special Needs Trust
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