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#146974 - 01/08/04 02:43 PM ITF vs Trustee
complyguy Offline
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complyguy
Joined: May 2001
Posts: 494
PA
Could someone please steer me toward the part of the PA Banking Code that states the ownership rights or other legal distinctions of each of these account titles? I've searched to no avail.

Our customer service staff disagrees on whom must be identified for CIP, and the teller staff is having fits with our new teller system's requests for info on the transaction conductor vs. the beneficiary.

Thanks in advance.

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#146975 - 01/08/04 02:59 PM Re: ITF vs Trustee
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
I can't point you to any code, but I'll share how we differentiate between these types of accounts. Generally, addding an ITF designation with a beneficiary does not change the ownership of the account. The grantor is still the owner, and can change/revoke the trust at any time.

Listing a non-owner trustee is something we do less frequently. (Burial reserves, for example.) We use this in instances when the trustee is not the grantor.

In either instance, for CIP, we refer back to the 'person that establishes the account' rule, generally the trustee. The beneficiary, IMO, almost never meets the CIP definition of customer.

On a side note, what operational snags are you running into with your teller system?

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#146976 - 01/08/04 09:47 PM Re: ITF vs Trustee
complyguy Offline
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complyguy
Joined: May 2001
Posts: 494
PA
A trustee opened three trustee accounts with > $10,000 cash. For CIP purposes, the CSR properly obtained info on the person opening the account. The teller system asks for conductor and beneficiary information for transactions at lower aggregating threshold. For the CTR generated, the teller system asked for the trustee's info (which we had) for Part B, but we needed all the same info (which we didn't have) for each of the three children for Part A.

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#146977 - 01/08/04 09:53 PM Re: ITF vs Trustee
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
That makes much more sense now. From your original post, I thought your teller system was looking for CIP information on the beneficiaries.

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