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The RCC had previously determined that the JFCS Trust met some but not all of the requirements for an exception (see previous opinions below). The amended JFCS Trust now requires reimbursement to all States that provided medical assistance under a State Medicaid plan. A transfer under this article does not create any rights in the beneficiary to compel distributions and shall not result in any disbursement of funds other than to the second nonprofit pooled trust or for the payment of taxes, fees and expenses associated with termination of the sub-account, compensation to the trustee, and costs associated with investment, legal or other services on behalf of the beneficiary. Therefore, aside from payments for goods or services for the trust beneficiary and reasonable administrative expenses, the trust must not (1) provide a benefit to any other individual or entity during the disabled individual’s lifetime, or (2) allow for termination of a trust account prior to the individual’s death and payment of the assets to another individual or entity. Social Security Act § 1917(d)(4)(C)(iii); POMS SI 01120.199. Accordingly, the Amended JFCS Trust satisfies the requirements to be excepted from resource counting. A transfer under this provision shall not result in any disbursement other than the transfer of funds to the successor trust and the payment of taxes and reasonable administrative fees and expenses. The Trustee Agreement states that “[u]pon JFCS’s resignation as Co-Trustee, the Beneficiaries shall become beneficiaries of the [SF Trust]” but does not require those beneficiaries to execute Joinder Agreements for the SF Trust. P~ and L~ did not execute Joinder Agreements for the SF Trust. QUESTION The P~ and L~ trust accounts are not excepted from resource counting under § 1917(d)(4)(C) of the Act.