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#1123789 - 02/05/09 05:31 PM Beneficiaries
mbernard Offline
100 Club
Joined: Jul 2008
Posts: 109
What is required information on a Beneficiary of an account? I know waht we would like to have, but what are we required to obtain at account opening? Just the name? Or do we need SSN and Address?

Thanks in advance.

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BSA/AML/CIP/OFAC Forum
#1123851 - 02/05/09 05:58 PM Re: Beneficiaries mbernard
NLC Offline
Gold Star
Joined: Jun 2005
Posts: 287
Center of US
You might want to look at your state law.
As far as what you must have I believe you only have to have name(s) and how to divide the funds but to help protect yourself later on the more info you can get the better. I would try and get full name, address, SSN. That way if later on one of the beneficiaries has died you can track down family etc.

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#1124448 - 02/06/09 12:55 PM Re: Beneficiaries mbernard
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
A POD beneficiary is not "a person opening an account" and is, thus, not a customer subject to your CIP unless your bank has chosen to include them.

Oftentimes, banks required detailed information on IRA beneficiaries because there are income tax implications to inheriting an IRA.

If it's not required by your bank's policies, it's simply not required.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1124452 - 02/06/09 01:12 PM Re: Beneficiaries Elwood P. Dowd
JimK Offline
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Joined: Oct 2002
Posts: 107
Alexandria, VA
We ask for identifing information on beneficiaries, not for CIP requirements, but in order to have identifying information regarding that person in the event the owner(s) of the account die. We have encountered situations where the bnf is not a family member, no family survivors and are unable to locate the bnf whose name is Smith, Johnson, etc. The funds may then get submitted to state as unclaimed property
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#1136761 - 02/26/09 07:18 PM Re: Beneficiaries JimK
mmumm Offline
100 Club
Joined: Jul 2008
Posts: 163
Santa Cruz, California
we are a state-chartered non-member bank - can we actually REQUIRE that we have the beneficiary's SSN, or can we just ASK, but the customer can refuse?

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#1137865 - 02/27/09 10:19 PM Re: Beneficiaries mmumm
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You and your customer both have freedom of choice; i.e. you may require the beneficiary's identifying information and thumbprint. In turn, your customer can tell you to take a long walk on a short pier.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1138347 - 03/02/09 05:46 PM Re: Beneficiaries Elwood P. Dowd
mmumm Offline
100 Club
Joined: Jul 2008
Posts: 163
Santa Cruz, California
we are located in California-can anyone point me to a specific law/regulation that speaks to this?

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