Custodian vs dealer vs depository: the three firms behind every gold IRA, and what each one owes you.
Every gold IRA is assembled from three separate companies, and the one that phoned you carries the least responsibility for your money. This page sets out custodian vs dealer vs depository properly: which firm holds the account, which holds the metal, which earns on the trade, who bills you for what, who each one answers to, and which of the three to call when a shipment, a statement or a storage line looks wrong.
Advertising disclosure: Gold IRA Consulting is reader-supported. We may earn a commission when you open an account through some links on this page (marked sponsored). This never influences our editorial scores, which are based on independent research.
- →Dealer sells the metal. Custodian holds the account. Depository holds the bars. Three companies, three contracts, and only the middle one has a trustee obligation to your IRA.
- →Money reaches all three by different routes. Two of them invoice you. The dealer does not, because its earnings live inside the price you pay for the coins.
- →None of the three is endorsed by the IRS. What exists is a published list of trustees and custodians cleared under one Treasury regulation, and that clearance says nothing about coins, prices or sales practice.
- →Your dealer normally selects the other two on your behalf. That is not improper, but it means the schedule you will pay for decades was chosen by the party whose promotion covers one year.
One phone call, three counterparties
All the advertising in this industry comes from a single type of business, and it is not the one that will end up holding your retirement money. A gold IRA is assembled from three firms with three jobs, three ways of getting paid and three different bodies looking over their shoulder. Once you can name which is which, most of the confusing parts of the process stop being confusing.
The dealer is a precious-metals sales company. It buys bullion wholesale, quotes it to you retail, fills the order and keeps the difference. It runs the ads, it employs the representative you spoke to, and it is usually the only one of the three whose name you knew before you started. It holds no title to anything of yours and files none of your tax paperwork.
The custodian holds the account rather than the metal. Your IRA is legally a trust or a custodial account, so something has to sit in the trustee's chair, and federal regulation limits who may: a bank, or an applicant the Commissioner has cleared under Treasury Regulation 1.408-2(e). The custodian records what the IRA owns, releases cash only on your written direction, values the account annually and files the year-end forms.
The depository holds the metal rather than the account. It is a commercial vault operator that takes delivery from the dealer, verifies weight and purity on intake, allocates the bars to your holding, insures the building and the contents, and reports the position back to your custodian. Note the direction of that last sentence. The vault reports to the custodian, because the custodian is its client.
Two neighbouring questions have their own pages, so they get one line each here. Which coins and bars qualify at all is decided by fineness thresholds, set out on our page covering IRA-approved gold. Where the metal is permitted to sit, and how segregated arrangements differ from commingled ones, is covered on our gold IRA storage page.
Custodian vs dealer vs depository, answered on the eight questions that matter
Read down a column to understand one firm. Read across a row to see how differently the same question lands on each of them. The final row is the one buyers almost never ask until it is too late to matter.
| THE QUESTION | DEALER | CUSTODIAN | DEPOSITORY |
|---|---|---|---|
| What is it, legally? | A retail sales company. No charter, no trustee duty, no fiduciary standard owed to you. | A bank, or a nonbank applicant cleared by the Commissioner under Treas. Reg. 1.408-2(e). | A commercial vault business. Not a bank and not a trustee. |
| What does it hold? | Inventory it intends to sell. Nothing belonging to your IRA. | Legal title to everything inside the account, cash included. | Physical bars and coins, allocated to your holding through the custodian. |
| Who picked it? | You did, in response to an advertisement. | The dealer proposed it, unless you asked to see alternatives. | The custodian's approved list, narrowed by the dealer. |
| How does it earn? | Margin above spot when you buy, margin below spot when you sell. Never itemised. | A published schedule: setup, annual administration, transactions, termination. | An annual storage and insurance rate, usually collected for it by the custodian. |
| Who supervises it? | No banking authority. Selling bullion requires no federal licence. | A state or federal banking authority for chartered institutions; the IRS for nonbank trustees. | Its state of incorporation, its auditors and its insurers. No federal bank examiner. |
| May it tell you what to buy? | Yes. Recommending product is the entire business. | No, and a serious one declines when asked. | No. It never sees the sales conversation. |
| Where does it show up on paper? | As the counterparty named on the purchase confirmation. | As the issuer of the statement and the filer of Forms 5498 and 1099-R. | As the storage location, plus one annual line on the same statement. |
| What if it fails? | Your metal does not move. You lose the buyback outlet it promised. | Account agreements provide for transfer of the accounts to a successor trustee. | Allocated metal is your property rather than the vault's asset, and it is insured. |
Trustee eligibility and the clearance standard from 26 CFR 1.408-2(e) and the IRS list of approved nonbank trustees and custodians, retrieved 12 August 2026. Role boundaries from custodian account agreements and depository disclosures as cited in our own research. Failure outcomes describe the standard allocated-storage arrangement and are not legal advice.
Three streams of money, and only two of them arrive as a bill
Money leaves your account in three directions at once, and the directions behave nothing alike. Two are invoiced, dated and disputable. The third is embedded in a price, settles instantly and leaves no line item to argue with. The figures below were taken from published schedules and stamped when we read them.
| STREAM | WHO SETS THE RATE | WHO COLLECTS IT | WHAT IT LOOKS LIKE, VERIFIED JUN 2026 | WHEN IT LANDS |
|---|---|---|---|---|
| Metal margin over spot | Dealer | Nobody. It is inside the purchase price. | Roughly 3% to 8% on common bullion; 20% to 40% or more on proof and collectible product. | Once, on the trade date. |
| Buyback margin under spot | Dealer | Nobody. It is inside the price you are offered. | Tight on liquid bullion, wide on high-premium coins. Quoted on the day, rarely published. | Once, when you exit. |
| Account setup | Custodian | Custodian, though a dealer promotion sometimes covers it | Commonly $50 to $80. Equity Trust lists $50 online or $75 on paper, STRATA $50 waived for electronic applications, GoldStar $50. | Once, at opening. |
| Annual administration | Custodian | Custodian | GoldStar Trust $90 flat, STRATA Trust $150 flat, Equity Trust scaled from $350 under $50,000 up to $2,500 above $1,000,000. | Every year, for the life of the account. |
| Storage and insurance | Depository, then re-priced by the custodian | Custodian, on the same statement | Delaware Depository charges $0.80 per $1,000 commingled with a $95 minimum, and $1.60 per $1,000 segregated with a $190 minimum. Custodian storage lines sit above that: STRATA $115 commingled and $175 segregated, Equity Trust $110 non-segregated and $160 segregated. | Every year, alongside administration. |
| Wires and transactions | Custodian | Custodian | Roughly $25 to $40 per outbound wire, plus per-transaction charges at some firms. | Per movement. |
| Termination | Custodian | Custodian | Equity Trust $250 full termination, STRATA $250 account closure, GoldStar $150. | Once, on the way out. |
Custodian figures read from each firm's own published fee schedule and detailed on our gold IRA custodians page. Delaware Depository rates from a custodian depository election form. Margin ranges from our own dealer research on the gold IRA fees page. Fees verified Jun 2026, confirm current pricing before you fund anything.
The proportions are the point. Administration and storage together commonly run $200 to $300 a year, an amount you will notice and can shop for. A margin decision made in a single phone call is worth multiples of that immediately, which is why the cheapest custodian in the table can still be attached to the most expensive account on the street. We take the administrative side apart on the gold IRA fees page and let you model your own balance in the fee calculator. What belongs here is the structural lesson: you can only negotiate a stream that somebody has agreed to name.
Nobody in this chain is endorsed by the IRS, whatever the advertisement implied
The phrase does real damage, so it is worth killing properly. The IRS maintains exactly one relevant list, and it is a list of entities cleared to serve as nonbank trustees or custodians under Treasury Regulation 1.408-2(e). The edition published on the agency's own page is dated April 1, 2026. There is no companion list of blessed dealers, no register of sanctioned vaults, and no coin that carries a government seal of approval.
Notice also who is missing from that list, and why. A bank does not appear on it and has no reason to, because a bank already satisfies the statute without applying to anyone. So a trust company being absent from the list proves nothing on its own, and a firm waving the list as a credential is telling you only that it is not a bank.
What does the clearance actually examine? Read the regulation and the answer is unambiguous: the applicant, and only the applicant. It must show that ownership is diverse enough that a death or a sale will not interrupt the work, so an individual can never qualify. It must keep a place of business in the United States that is reachable on every business day. It must prove fiduciary experience, solvency, and competence at accounting for the interests of a large number of individuals at once. Initial applications since January 1995 require net worth of at least $250,000. Fiduciary books must be audited annually by a qualified public accountant, and assets requiring safekeeping must go into an adequate vault with a permanent record of everything deposited or withdrawn.
Every one of those tests is about administration. Not one of them looks at a coin, a premium, a sales script or a buyback promise. The Securities and Exchange Commission draws the conclusion in a single sentence in its investor alert on self-directed accounts: using a legitimate custodian to buy an investment does not make that investment legitimate. The same alert warns that fraudsters routinely misrepresent what custodians do, implying that the trustee has investigated and validated whatever is being sold. It has not, and it will tell you so if you ask.
The three claims to strike from any pitch
- "IRS-approved dealer." No such status exists. Selling bullion carries no federal licence and no banking supervision, which is why the dealer column above is the thinnest one in the whole table.
- "IRS-approved depository." Also not a thing. The requirement is that qualifying metal stays in the physical possession of the trustee, so what matters is that your custodian directs the vault, not that the vault holds a certificate. Our storage page covers how that possession requirement works.
- "IRS-endorsed" anything. Clearance under a regulation is permission to administer accounts. It is not an opinion on price, product or firm, and treating it as one is precisely the error the SEC alert describes.
Regulation of the other two runs elsewhere. Chartered trust companies answer to a state banking department or a federal banking regulator, which is a live supervisory relationship with examinations behind it. Vault operators answer to their state of incorporation, their auditors and the insurers who underwrite the all-risk cover, and one of the vaults in common use is administered by a state directly. Dealers answer to general consumer-protection law and to their own customers, which is a genuinely lower bar and the reason this industry rewards documentation over trust.
How the three firms actually interact when you buy
Follow one purchase from signature to shelf and the division of labour becomes obvious. Each numbered step changes hands. If your provider describes a sequence that skips one of them, that is the question to ask.
- 1You sign two agreements, not one. The dealer's order paperwork and the custodian's account application are separate contracts with separate counterparties. If only one document ever reaches you, ask for the other.
- 2The custodian opens the account and numbers it. At this moment you own an empty self-directed IRA. Nothing has been purchased and no metal exists anywhere in your name.
- 3Cash settles at the custodian. Your transfer or rollover lands in the IRA at the trustee, never at the sales company. This is the single most useful structural check available to a first-time buyer.
- 4The dealer quotes product and price. Live metal prices move, so a figure discussed at application is indicative. The number that binds is the one on the confirmation, struck the moment the order is locked.
- 5You direct the custodian, in writing, to pay. The trustee is executing an instruction here, not exercising judgement. This is the step that makes the account self-directed and the reason nobody at the custodian will tell you whether the trade is wise.
- 6The custodian releases funds against the invoice. Cash moves from your IRA to the dealer for the products named on that invoice, which is why any mismatch between quote and invoice must be resolved before this step, not after.
- 7The dealer ships to the vault, addressed to the custodian. The consignment travels to the depository under the custodian's account, not to your home and not in your name, and it is insured in transit.
- 8The depository verifies, allocates and reports. Intake checks weight and purity, the holding is allocated to your account, and the position flows back to the custodian. Your first statement is the moment the loop closes, and it is the document worth reading line by line.
Any tax consequence of what happens next is a separate subject: distributions, not purchases, are what the code taxes, and we cover the treatment on how a gold IRA is taxed. Steps one to eight are not taxable events.
When something goes wrong, work out who to call before you call
Most complaints in this industry begin with a buyer describing a vault problem to a salesperson, or a pricing problem to a trust company. Both calls fail, and the failure gets read as stonewalling. Match the symptom to the firm that owns it and the conversation changes character immediately.
| THE SYMPTOM | WHOSE PROBLEM | WHY IT SITS THERE | WHAT TO ASK FOR, IN WRITING |
|---|---|---|---|
| The products delivered are not what was discussed | Dealer | It selected, priced, invoiced and shipped them. | The signed confirmation and the invoice showing product, quantity and any serial numbers. |
| You suspect you paid far above the market | Dealer | Margin is its revenue and appears in no fee schedule anywhere. | The buy price against spot on the trade date, plus today's buyback bid on the same items. |
| The statement shows the wrong quantity or value | Custodian | It produces the statement and reports the account to the IRS. | A corrected statement, and the depository holdings report it was built from. |
| A distribution was reported incorrectly, or no form arrived | Custodian | It is the filer of Forms 5498 and 1099-R for the account. | A written correction and confirmation of what was transmitted to the IRS. |
| Metal is short, damaged or unaccounted for in the vault | Depository | It took intake custody, insures the holding and reports the position. | The intake report, the audit date, and the claim route under the all-risk policy, pursued via your custodian. |
| Fees you were told would be waived appeared on the bill | Usually the dealer, though the invoice is the custodian's | Promotions are made by the sales company; the trust company bills its own published schedule. | The waiver in writing from the party that will honour it, naming the fee, the year and the condition. |
| Nobody will answer at all | Custodian | It is the only one of the three holding a signed account agreement with you. | A written instruction under that agreement, and its published complaints process. |
Allocation of responsibility reflects the standard contractual structure described in custodian account agreements and depository disclosures reviewed for this page. It is a practical triage guide, not legal advice, and it does not replace the terms of your own agreements. Our ranking methodology explains how we treat unpublished provider claims.
The sales company picks the other two, which is exactly why you should look
In practice the order of selection is fixed. You choose a dealer, the dealer proposes a custodian it already works with, and that custodian offers a short list of vaults. Nobody is hiding anything. It is simply faster, and a routed application opens in days rather than weeks. The cost of the convenience is that the two firms you will still be paying in 2040 were both selected by the one whose promotion expires after twelve months.
Three consequences are worth the ten minutes it takes to check. First, the shape of the custodian's schedule outlives every waiver: a flat annual figure and a schedule that scales with account value diverge sharply once a balance passes six figures, and that divergence dwarfs the setup fee somebody waived to win you. Second, the vault decides what storage arrangements are even available to you and what each one costs, and segregated always prices above commingled. Third, a custodian that names several depositories gives you a second decision later; one that names a single vault has made it for you.
So ask four questions before you sign anything, and ask for the answers in the same email as your quote: which custodian will administer this account, which schedule applies to it, which depository will hold the metal, and whether segregated or commingled storage is being assumed. A firm that answers all four in writing has told you more about itself than any testimonial could.
Two companion pages go deeper than this one can. Our page on gold IRA custodians prints the published schedules of the firms that administer most of these accounts, names the regulator behind each and shows which dealers route business where. Our page on gold IRA depositories does the same for the vaults, including the storage rates each one will actually put in a document. Both are new additions to the Learn centre and are the natural next step from here. When you are ready to compare the sales side, our gold IRA company rankings score the ten dealers we track.
Questions buyers ask once they notice three companies on the paperwork
What is the difference between a custodian vs dealer vs depository in a gold IRA?
The dealer sells you the metal and earns the spread between what it pays for bullion and what you pay for it. The custodian holds the account: it is a bank, or a nonbank trustee the IRS has approved under Treasury Regulation 1.408-2(e), and it carries legal title inside the IRA, moves cash only on your written direction, and files Forms 5498 and 1099-R. The depository holds the metal: a commercial vault that receives the shipment, verifies it, allocates it to your holding, insures the building and reports back to the custodian. Three firms, three revenue models, three answers to the question of who is accountable. The one advertising to you is the dealer, and it is the only one of the three with no chartering authority standing behind it.
Can the same company be my dealer and my custodian?
Not in any structure we have reviewed, and you should treat a claim to the contrary as a reason to slow down. The trustee role is restricted by regulation to banks and to nonbank applicants the Commissioner has approved, and the approval process is about administering trusts rather than about selling anything. A sales company that also held title to your metal would be quoting the price, taking the money and writing the statement that confirms the price. The practical test is simple: watch where your rollover cash settles. It should land in an account at the custodian in your IRA's name. Funds that settle at a metals dealer's own bank first are a structural problem, not a paperwork quirk.
Is my gold IRA custodian approved or endorsed by the IRS?
Approved is sometimes accurate. Endorsed is never accurate, for any of the three firms. The IRS publishes a list of entities cleared to serve as nonbank trustees and custodians under Treasury Regulation 1.408-2(e); the current edition is dated April 1, 2026. A bank does not appear on it and does not need to, because banks already qualify. What the clearance examines is the applicant: ownership continuity, an established United States place of business, fiduciary experience, solvency, the ability to account for many individuals at once, net worth of at least $250,000 at initial application, and annual audits of the fiduciary books by a qualified public accountant. None of that examines a coin, a price or a sales pitch. The SEC puts the consequence bluntly in its investor alert on self-directed IRAs: using a legitimate custodian to buy an investment does not make that investment legitimate.
How many separate bills should a gold IRA generate?
Usually two invoices covering three streams of money. The custodian bills its own setup, annual administration, transaction and termination fees. Storage and insurance are set by the vault but in most arrangements are collected through the custodian, so they land on the same statement. The third stream never arrives as a bill at all: the dealer's margin is inside the price of the metal on the day you buy, and its buyback margin is inside the price on the day you sell. That is why a buyer can be certain there are no hidden fees and still have paid the largest single cost in the account on day one. Ask for the buy price against spot on the trade date, in writing, alongside the fee schedule. Fees verified Jun 2026, confirm current pricing.
If my gold dealer goes out of business, what happens to the metal?
Nothing moves. The bars and coins sit in the depository, allocated to your IRA and titled through your custodian, and the dealer that arranged the purchase has no claim on them and no ability to instruct the vault. What you lose is commercial rather than custodial: the firm that promised to buy the metal back is gone, so your exit becomes a shopping exercise across other dealers rather than one phone call. That is a real cost on illiquid or high-premium products and close to nothing on standard bullion. It is also the reason a buyback promise from a sales company is worth less than a purchase decision that keeps you in liquid metal.
Does the depository work for me or for my custodian?
For your custodian, in almost every gold IRA. The vault's contract, its reporting obligation and its billing relationship run to the custodian, which is why a call from an account holder asking a depository to confirm holdings is usually redirected. You are the beneficial owner of allocated metal, but you are not the vault's client. Two practical consequences follow. First, the holdings report you are entitled to see comes through your custodian, so ask the custodian for it rather than the vault. Second, if metal is short, damaged or missing, the insurance claim is pursued by the custodian under the depository's all-risk policy, and your job is to document what your statement said it held.
Related reading: the custodian schedules compared, the vaults compared, the full cost breakdown, and our dealer rankings.
Trustee eligibility and the meaning of IRS clearance come from federal primary sources, retrieved 12 August 2026. Fee figures come from published schedules and were verified Jun 2026; confirm current terms with each firm before funding.
- 26 CFR 1.408-2, Individual retirement accounts: paragraph (e) sets the standard a nonbank applicant must meet, including ownership continuity, an established United States place of business, fiduciary experience and responsibility, capacity to account for a large number of individuals, initial net worth of at least $250,000, annual audits of the fiduciary books by a qualified public accountant, and safekeeping of assets in an adequate vault.
- IRS, Approved nonbank trustees and custodians: the agency maintains a list of entities approved under Treasury Regulation 1.408-2(e) to serve as nonbank trustees or custodians. Current edition dated April 1, 2026; page last reviewed 28 June 2026.
- SEC Office of Investor Education and Advocacy, Investor Alert: Self-Directed IRAs and the Risk of Fraud: custodians of self-directed accounts do not evaluate the quality or legitimacy of an investment or its promoters, do not verify financial information supplied about it, and using a legitimate custodian does not make an investment legitimate.
- Custodian setup, administration, storage and termination figures read from each firm's own published fee schedule and set out in full on our custodians page. Delaware Depository rates taken from a custodian depository election form.
- Dealer margin ranges from our own pricing research, published on the gold IRA fees page. Margins are quoted per transaction and are not published by any dealer we track.
Nothing on this page is legal or tax advice. The accountability table describes the ordinary contractual arrangement between these three types of firm and is not a substitute for the agreements you sign.
Find out who the other two firms are before you sign
Our free kit includes the custodian and storage schedules behind this page, plus the four questions to send any provider before you fund an account. Then compare the sales side on our rankings.