Following Trust under Agreement of Edward Winslow Taylor, 640 Pa. 629, 164 A.3d 1147 (2017), a trust cannot be modified to allow the beneficiaries to remove and replace trustees even with the consent of the settlor under 20 Pa.C.S. § 7740.1(a). Garrison Trusts, 10 Fid.Rep.3d 189, Nos. 1992-X1509, 1992-X1518, and 1992-X1519 (Montgomery O.C. 6/16/2020), aff’d 1429 EDA 2020 (Pa. Super. 9/27/2021) (non-precedential), rev’d, ___ Pa. ___, ___ A.3d ___, 61 MAP 2022, 62 MAP 2022, and 63 MAP 2022 (1/19/2023).

[DBE Note: This decision is almost certainly wrong. It relies entirely upon the failure of the Taylor court to distinguish between subsections (a) and (b) of § 7740.1, and so reaches a result that the Taylor court never considered.]

[Updated on 1/27/2023 to show that the Supreme Court reversed the Superior Court and Orphans’ Court.]