Until enactment of the "Special Needs Trust Fairness Act" provisions of the 21st Century Cures Act in late 2016, a first party/self-settled trust had to be created by a parent, grandparent, guardian, or court. The statute did not allow the disabled individual to create his or her own trust, even if he or she was otherwise legally competent. The 21st Century Cures Act amended 42 U.S.C. §1396p(d)(4)(A), by adding "the individual" to the list of people who can establish a first party trust.