Provision record
Robinhood · Robinhood Customer Agreement (PDF) · View original document ↗

Custodial Account Custodian Personal Liability and Gift Reversal Obligation

Medium severity Medium confidence Explicit document language Unique · 0 of 352 platforms
Stay ahead of the changes
Track Robinhood and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

If a third-party donor's gift to a custodial account is reversed or challenged for any reason including ACH reversal or fraud, the custodian bears personal financial liability for the reversed amount, with no obligation on Robinhood to pursue recovery from the donor.

ⓘ

This analysis describes what Robinhood's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision assigns personal financial liability to the custodian for reversed or fraudulent third-party gifts to a minor's custodial account through the optional gifting feature, with recovery by Robinhood subject to the right of offset established in Section 31.8.

⚠

Interpretive note: The enforceability of personal custodian liability for third-party donor reversals may vary under applicable state UTMA fiduciary law depending on the jurisdiction.

Recent Activity

This document changed recently

Medium Jul 12, 2026

The updated terms establish new fiduciary verification and personal liability provisions for trust and custodial accounts. Trustees are now required to complete Robinhood's identity verification and onboarding before accessing trust accounts, notify Robinhood promptly of any material changes to the trust (amendments, revocation, trustee changes), and provide the correct taxpayer identification number for the trust. The revised language states that trustees are personally liable for obligations, debts, or negative equity arising from instructions given outside the scope of their authority under the trust instrument or applicable law. Robinhood reserves the right to freeze trust accounts or request updated documentation at any time, and will rely on instructions from any onboarded trustee without requiring consent from co-trustees or verifying compliance with the trust instrument. You should consult a tax advisor regarding the appropriate taxpayer identification number for your trust and review your fiduciary authority under the applicable trust instrument before executing trades.

View change record →

Consumer impact (what this means for users)

Under this clause, a custodian who enables the gifting feature becomes personally liable for any gift that is reversed, returned, or challenged, including reversals resulting from donor fraud or ACH failures, with Robinhood authorized to recover the amount through the right of offset described in Section 31.8.

Cross-platform context

See how other platforms handle Custodial Account Custodian Personal Liability and Gift Reversal Obligation and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
If a Donor's gift is reversed, returned, or challenged for any reason, including but not limited to ACH reversals or fraud, you agree that such reversal creates a personal Obligation for which you are liable. This Obligation is governed by the personal responsibility and recovery rights described above, including the Right of Offset in Section 31.8 and the custodial limitations (i)-(iv) applicable to such recovery. You acknowledge that Robinhood has no obligation to pursue a Donor for a reversed gift and that any recourse for the value of the gift is solely between you and the Donor.

Excerpt from Robinhood's Customer Agreement (PDF)

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: Custodial account obligations are governed by applicable state UTMA and UGMA statutes, which define the custodian's fiduciary duties and personal liability.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • CFPB
    The CFPB has authority over consumer financial protection implications of liability allocation provisions in consumer financial agreements.
    File a complaint →
  • State AG
    State attorneys general may evaluate custodial account personal liability provisions under applicable state UTMA law and state consumer protection statutes.
    File a complaint →

Provision details

Document information
Document
Robinhood Customer Agreement (PDF)
Entity
Robinhood
Document last updated
May 5, 2026
Tracking information
First tracked
Sept. 21, 2026
Last verified
Sept. 21, 2026
Record ID
CA-P-077578
Document ID
CA-D-00050
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
6c1624e8d37bd37409c5615a2845984e57c7d88ba5c20ddc802d07565e5df5dd
Analysis generated
September 21, 2026 01:55 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Robinhood
Document: Robinhood Customer Agreement (PDF)
Record ID: CA-P-077578
Captured: 2026-09-21 01:55:39 UTC
SHA-256: 6c1624e8d37bd374…
URL: https://conductatlas.com/platform/robinhood/robinhood-customer-agreement-pdf/provision/CA-P-077578/custodial-account-custodian-personal-liability-and-gift-reversal-obligation/
Accessed: Oct. 2, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Robinhood's Custodial Account Custodian Personal Liability and Gift Reversal Obligation clause do?

This provision assigns personal financial liability to the custodian for reversed or fraudulent third-party gifts to a minor's custodial account through the optional gifting feature, with recovery by Robinhood subject to the right of offset established in Section 31.8.

How does this clause affect you?

Under this clause, a custodian who enables the gifting feature becomes personally liable for any gift that is reversed, returned, or challenged, including reversals resulting from donor fraud or ACH failures, with Robinhood authorized to recover the amount through the right of offset described in Section 31.8.

Is ConductAtlas affiliated with Robinhood?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Robinhood.