Our CIP states that we identify the person opening the account for someone that lacks legal capacity. This is backed up in the FAQ from FinCEN (Question #1 under "Definition of Customer")
The IRA manual from Bankers Systems states that the financial organization must apply its CIP to the designated beneficiary of a CESA and should apply it to the contributors and/or responsible individuals. I think this is in conflict with the regulation. Thoughts?
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David J Mulkerin, CRCM
All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.
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