Gold IRA Custodians: How to Verify One Against the IRS List Before You Sign
Short answer. A custodian is the legal administrator of your IRA. It holds title, executes your instructions, arranges storage and reports to the IRS. It does not advise you and it does not pick your metal.
There is one authoritative way to check whether a non-bank custodian is approved: the IRS list of approved nonbank trustees and custodians, published on irs.gov under Treasury Regulation § 1.408-2(e). It is free, it is searchable, and it takes two minutes. Do that before you sign anything.
The check almost nobody tells you to do
Sales material in this industry leans on the phrase "IRS approved" without ever pointing at a document. For custodians there genuinely is one, and it is the single most useful two minutes you will spend on this decision.
Under Treasury Regulation § 1.408-2(e), an entity that is not a bank cannot act as an IRA trustee or custodian unless it has applied to the IRS and been approved. The IRS publishes the resulting list and updates it as entities are added or removed, including removals following a withdrawal or revocation.
Verify a custodian in two minutes
Answer these about the company you are considering. Nothing is sent anywhere, this runs in your browser.
The list is at irs.gov, approved nonbank trustees and custodians. Match the exact legal entity name, not the brand on the website, because marketing names and charter names often differ.
What the custodian does, and what it will not do
| The custodian does | The custodian does not |
|---|---|
| Hold legal title to the assets on behalf of the IRA | Advise you on whether to buy metal at all |
| Execute the instructions you give it | Choose which coins or bars you end up with |
| Arrange storage at a depository | Guarantee the price you pay to the dealer |
| Keep records and file the required IRS reports | Vet the dealer's pricing on your behalf |
| Process contributions, transfers and distributions | Take responsibility if the asset falls in value |
That right-hand column matters. A custodian permitting a purchase is not a custodian endorsing it. Their job is administration, and self-directed means the direction genuinely comes from you.
The fees, and the one that is not theirs
We do not publish a fee table on this page, and the reason is deliberate: these schedules change, they vary by account size, and a figure that is six months stale is worse than no figure because you will negotiate against it. Ask for current numbers in writing and compare these four lines.
| Line | Charged by | What to ask |
|---|---|---|
| Setup | Custodian | Is it waived above a certain balance? |
| Annual administration | Custodian | Flat, or a percentage of value? |
| Annual storage | Depository, often billed via the custodian | Flat or percentage, and segregated or commingled? |
| Spread on the metal | The dealer, not the custodian | What would you pay me for this same coin today? |
The last line is usually the largest single cost in the whole arrangement and it is not the custodian's fee at all. Comparing custodians on administration fees while ignoring the dealer spread is optimising the small number. Ask for the same-day buy and sell price on an identical product, and the difference between those two is your real entry cost.
Flat or percentage, over a long retirement
This choice looks trivial at opening and compounds for decades. A flat annual fee is a shrinking percentage as the account grows. A percentage-based fee grows with the balance, and it is charged on the value of an asset that produces no income to pay it from. On a large account held for twenty years the difference between the two structures is not a rounding error. Ask for both quoted on your actual expected balance.
Warning signs
Red flag Home storage is offered
Any arrangement where you end up holding the metal, including a checkbook LLC marketed as a home storage IRA, is the structure the Tax Court ruled on in McNulty v. Commissioner (2021). A custodian raising this as a feature is telling you something important about the custodian.
Red flag The dealer picks the custodian for you
You choose all three parties. If a dealer will only work with one custodian and will not explain why, that is a bundling arrangement, and bundles are where undisclosed margin lives. Ask whether you can use a custodian of your own choosing and listen to how the answer is phrased.
Red flag Urgency about the metal, not the paperwork
Transfers take a couple of weeks and no legitimate deadline depends on you deciding today. Pressure framed around the price of silver rather than an actual administrative cutoff is a sales technique.
Red flag "IRS approved" with nothing to point at
For a non-bank custodian, "IRS approved" is a checkable claim. Ask them to tell you the exact legal name they are listed under, then check it yourself. A company that cannot answer that question quickly is either not listed or does not understand its own status.
Red flag Advice from the administrator
A custodian recommending specific coins, promising returns, or telling you how much of your retirement to move is stepping outside its role. Administration and advice are different functions and the firms that blur them are the ones that generate complaints.
A note on 2026
The rules around who may act as a nonbank trustee are not static. There has been movement this year on the criteria under which broker-dealers can qualify, which is why we point you at the live IRS list rather than reproducing a snapshot of it here. A list copied into an article is out of date the moment the IRS updates it. Check the source.
Questions people ask
Does the custodian have to be a bank?
No. Banks and federally insured credit unions qualify automatically. Everyone else must be approved by the IRS as a nonbank trustee or custodian and appear on the published list.
Can I change custodian later?
Yes, by trustee-to-trustee transfer, which is not a taxable event and has no annual limit. Ask about transfer-out and account-closing fees before you open, because that is when they are negotiable.
Who insures my metal?
The depository carries the insurance, not the custodian. Insurance covers loss and theft, not a fall in the price of silver. Ask for the specific terms rather than accepting the word "insured".
Can one company be custodian, dealer and depository?
Some groups offer more than one function under related brands. It is not automatically improper, but it removes the cross-checks that come from three independent parties, so ask directly who owns whom.
What happens to my account if the custodian fails?
The assets belong to your IRA, not to the custodian's balance sheet, and accounts are ordinarily transferred to another custodian. Ask what the documented succession arrangement is, because the answer tells you how seriously the firm plans.
Next
- The home storage claim, and the case that settled it
- Where the metal is actually stored, and why there is no IRS list of depositories
- Moving an existing account in, including the 20% withholding trap
- Which silver qualifies, straight from the statute
Primary sources
- IRS, Approved nonbank trustees and custodians, the authoritative list
- IRS, Application procedures for nonbank trustees and custodians
- Treas. Reg. § 1.408-2, including the nonbank trustee requirements at (e)
- McNulty v. Commissioner, 157 T.C. No. 10 (2021)
Metals Retirement is an independent research site. We are not a broker, dealer, custodian, law firm or investment adviser, and nothing here is investment, legal or tax advice. We deliberately do not reproduce the IRS list or any custodian's fee schedule, because both change and a stale copy is worse than none. Verify against the linked sources and your own written quotes. We may be compensated by providers we compare, at no cost to you. Last reviewed 26 July 2026.