Look to the purpose of the account in combination with the ownership.
For example, if an attorney maintains a trust account on behalf of her clients, the ownership may be individual if the attorney is a sole proprietor, but the purpose of the accounts is business. I would set it up as a business account.
On the other hand, with a rep payee account or its counterpart for VA funds, the ownership and purpose are both personal. I would set them up as personal (consumer) accounts.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8