For the estate account, your customer is the estate, not the individual opening it. Yes, you have to apply your CIP. You need to obtain the name of the customer (Estate of ______________), an address (in this case, generally the address of the personal representative), and an identifying number (which will NOT be an SSN; it must be the EIN issued to the estate by the IRS). No date of birth, obviously. You will verify the existence of the estate and the name of the personal representative using the Letters Testamentary (or whatever the document used by the Probate Court to designate the personal representative is called in your state). You will NOT use a document purporting to be the will of the decedent.
A prudent banker will also verify the identity of the personal representative. If the court document appoints Ken Golliher as the executor or administrator of the estate, you have to know that the dude opening the account is actually Ken Golliher, whether or not you're going to do the CIP dance with him.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8