Happy Holidays,

I am seeking wisdom around signature cards, specifically for Guardianship Accounts and UTTMAs. Is it customary that a financial institution requires ID for the protected individuals/beneficiaries of these respective accounts?

Example 1: Tiny Tim is a minor, age 16. Jane Doe is his custodian. (Our organization requires ID for the minor, even if he/she is a restricted minor)

Example 2: John Doe is a vulnerable adult. The court appoints Janice Shapiro-Doe to be his guardian. (Our organization requires ID for the vulnerable adult, even if he/she has no access to the account)

A lot of banks have adopted CIP requirements that go well beyond the minimum requirements of the regulation. They call for applying identification and verification standards to all authorized signers, as well as individuals such as the vulnerable adult or minor in your examples, when the regulation would not impose such requirements. I suppose it may be easier to train staff members to always obtain and verify ID on every individual associated with an account, but such expansive policy requirements often get banks into the swamp when they run into objections from authorized signers on non-profit organization accounts or accounts of major national businesses, or, at a community level, when beneficial ownership is held by a non-owner of the account (a minor under a UTMA account or a ward under a guardianship).

More reasonable (my opinion) CIPs call for limited information about beneficial owners -- SSN and DOB for a minor, for example, or SSN for a ward -- that is needed to administer the account, but stop short of calling for ID. And when it comes to authorized signers, many banks don't bother with CIP at all unless the individuals are key owners of a business.

So I can't say what is "customary" among banks in your area, but I have suggested what some of the options might be.

This is also assuming that when you use the term "custodian", it is in a legally defined manner, i.e. court appointed, UTMA, etc.

Thank you for the feedback!