Third-Party Protection Pooled Trust (PPT)

A Third-Party Protection Pooled Trust (PPT) allows the Grantor(s), the person(s) funding the trust, the opportunity to provide for a minor who does not have a disability or a vulnerable adult, and can benefit from having an experienced, compassionate, professional trust administrator.

Third-Party Protection Pooled Trust: Joining Documentation

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

Funding the Trust

A Third-Party Protection Pooled Trust is commonly funded through a Grantor’s will, estate plan, life insurance policy, or employee benefit. It can also be funded by a gift during the Grantor’s lifetime. CCT accepts cash assets for deposit into the trust. CCT can also accept residential Real Estate for use as the beneficiary’s home.


Once the Grantor completes the Joinder Agreement, the trust is established and ready to receive funding. There is no requirement that the account be funded immediately. Once funded, the trust may receive funds from multiple sources and at any time.


When appropriate, it is helpful to inform family members and other relevant parties about the Beneficiary’s trust account and direct that any intended gifts be made to the trust with CCT and not given or left directly to the individual (see sample letter).

How Funds in the Trust Can Be Used

In accordance with the Master Trust Agreement, CCT has discretion in approving disbursement requests. Each disbursement request is evaluated based on CCT’s fiduciary duty to its Beneficiaries, and through the Health, Education, Maintenance, and Support (HEMS) standard.


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 primarily for the benefit of the Beneficiary? 
    • Is the request aligned with HEMS - health, education, maintenance and support standards? 
    • Are there sufficient funds in the trust to cover the request? 
    • For minors, see page 2 of CCT's Disbursement Manual for special considerations. 

  • 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 Resources

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.

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.

Termination of a Third-Party Protection Pooled Trust Sub-account

The Third-Party PPT is designed for flexibility. The Grantor can designate in the Joinder Agreement an age for the trust to be terminated after the beneficiary reaches adulthood (18 or older). The Grantor can also elect to grant CCT discretion to make that determination.

Third Party Pooled Special Needs Trust

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 option can be incorporated into your estate plan. We are also accepting homes as part of transfers or decanting from existing trusts.


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

Third-Party PPT Real Estate Guidelines

Important Information

  • 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 Settlement Protection Pooled 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. 

  • Power of Appointment

    The Grantor may give the Beneficiary a general power to appoint the remaining balance of the trust account to successors of his or her choosing upon reaching the age of majority. The Beneficiary may exercise it by submitting a signed and notarized form to CCT, designating who will receive the remaining balance on the Beneficiary’s death.

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