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#1143596 - 03/11/09 06:04 PM CIP on Irrevocable Trusts
Trust Compliance Offline
Junior Member
Joined: Apr 2007
Posts: 25
If the Irrevocable Trust is the customer for CIP purposes, do you need to obtain CIP information on the beneficiaries only? Or, do you need to do CIP on the deceased Grantor? Thanks.

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#1143600 - 03/11/09 06:08 PM Re: CIP on Irrevocable Trusts Trust Compliance
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You perform CIP on the Trust. An Irrev Trust will have an EIN.
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#1143859 - 03/12/09 01:49 AM Re: CIP on Irrevocable Trusts BrendaC
BBoyd Offline
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BBoyd
Joined: Mar 2002
Posts: 2,494
MI
What about the Trustees of the Trust?
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#1143957 - 03/12/09 01:31 PM Re: CIP on Irrevocable Trusts BBoyd
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If your bank's CIP calls for obtaining and verifying ID info on the trustees, yes.

FWIW, because trusts themselves are so easy to fake, verification of their "identity" doesn't give me warm fuzzies. I'd always want to know about the trustees.
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John S. Burnett
BankersOnline.com
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#1143970 - 03/12/09 01:39 PM Re: CIP on Irrevocable Trusts John Burnett
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I personally think that verifying trustees is a reasonable KYC step and should be a standard practice when establishing a trust. Depending on the nature of the trust, verification of beneficiaries is also important to understand the ultimate beneficiaries of transactions. You might classify it more under CDD than CIP.
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