Comerica Bank

15 years into the partnership, TEAM is now an “integral part of Comerica’s business model” and has served as the employer of record for more than 400 trust-paid caregivers, who are often the parent or loved one of the beneficiary.


In 2007, Comerica’s Special Needs Trust business was growing rapidly. With branches across the U.S., Comerica’s trust officers were tasked not only with their fiduciary duties and the increasing list of compliance and regulatory responsibilities on their plates, but they also found themselves taking on the role of employer for the caregivers that were providing services to trust beneficiaries.
This included processing payments for an inconceivable amount of caregivers in multiple states throughout the country; staying up to date with the employment law landscape at the federal, state, county, and city levels; handling HR questions and issues raised by the caregivers; procuring necessary insurance to protect the bank in the event that a caregiver was injured or flagged a potential discrimination, harassment, or retaliation claim; as well as a variety of legal, financial, and administrative responsibilities that employers manage.

And while compliantly managing trusts was critical to their mission, the duties of being an employer often fell outside the scope of trust officers’ core competencies and added hours to their weekly workload.

Jacqueline O’Connor, National Director of Special Needs Solutions at Comerica, stated, “As a trust officer, our number one focus is always to mitigate the potential for liability. Yet we had no regularity or consistency in how we were paying caregivers. Each local trust advisor did it in their own way, and we had added risk since we weren’t providing caregivers with 1099s or W-2s.”

Comerica’s SNT Division


Jacqueline sought to change this. After researching various partners and approaches to alleviate the burden and complexity of managing trust-paid service providers, she met Terry Keating, Co-founder of TEAM Risk Management Strategies, at a Special Needs Trust conference.

Comerica’s SNT Division

“When I brought TEAM onboard, our trust officers appreciated the time they got back in their days.  They were no longer collecting timesheets or calculating hours worked by caregivers.  They also were no longer managing day-to-day issues or having to retain tax records or create payroll reports.”


15 years later, TEAM is now an “integral part of Comerica’s business model” and has served as the employer of record for more than 400 trust-paid caregivers, who are often the parent or loved one of the beneficiary, according to Jacqueline. “The caregivers, many of whom devote their entire life to providing support to the person they care for, are now tax-paying citizens who can purchase health insurance, apply for a home loan, save for retirement, and be an effective part of the economy. TEAM has brought legitimacy to their work in many ways, and the impact is tangible.”

TEAM’s model makes the process seamless for both the trust officers and the caregivers, as each party completes just a few forms to officialize the transition of employment. “TEAM is a vital partner. TEAM ensures all our caregivers are accounted for, job applications and background checks are complete, and hourly wages are set and processed in accordance with the law,” says Jacqueline.

Comerica’s SNT Division

Comerica has realized benefits beyond time savings and uniformity in its process. In fact, the organization has deflected hundreds of HR issues over the course of the partnership – ranging from timecard disputes to Workers’ Compensation claims and COVID-related concerns – with the help of TEAM’s HR experts. “TEAM has been useful from an HR perspective, too. We’ve had instances where there were HR issues, such as caregivers reporting overtime that wasn’t approved. Because the caregiver reports directly to TEAM, it’s handled without having to involve our trust officers or the bank. Most importantly, the trust is alleviated from potential liability, should a caregiver get hurt on the job.”

The nature of caregivers’ work is certainly strenuous, and also deeply personal. It’s critical that TEAM not only provides accurate payroll processing and compliant HR support, but serves Comerica’s clients with care, empathy, and patience. This doesn’t go unnoticed by Jacqueline: “TEAM knows our clients as well as we do.”

Comerica’s SNT Division