Law Firms as Trust Directors in North Carolina?

Professor Raymond C. O’Brien argues in a recent article entitled Law Firms as Trust Directors, 51 ACTEC L.J. 35 (Fall 2025) that law firms should serve as Trust Directors. It is not clear whether naming a law firm entity as a Trust Director is allowed in North Carolina given the January 7, 2026 case of In Re Russo, but probably not given that the definition of a “Power Holder” in NCGS 36C-8A-1(a)(2)(b) includes “One or more other persons each of which is qualified to exercise trust powers in this State.” This in combination with the language from the Russo case arguably means that law firms, as an entity, cannot serve as Trust Directors in North Carolina.