Hey Gang. Realizing that for purposes of CIP, the trust is the "customer" for a trust account, who then provides the DOB, address and identifying number? Is it the trustee, the trustor or none of the above? Lastly, would your answer be applicable to all fiduciary accounts, especially funeral trusts?

Anyone interested in taking a crack at this one? I'm stumped.

The Trust is the customer, so you would gather info on the Trust. The Trust does not have a DOB. The Trust should have a TIN and address, however.

You are always free to gather info on signers - in this case, the Trustees, but you're not required to do so.

But you do have to gather information on the signers who are in front of you when you open the Trust account(s), correct?

Not unless your policy calls for it. CIP does not require that you identify signers, just the customer, which in this case is the trust itself.