I'm sure this has been addressed here before- if so and someone has a link, please send it my way! I have a FBO account and have received a financial records subpoena for the person listed on this account. We've received garnishments for this person in the past but the funds have always been protected. The account is titled Defendant FBO Dependent in which the dependent's social security is direct deposited each month. The only SSN on this account is the Defendant's, which makes her an Owner. Am I wrong in my thinking?

What sort of SSI payments are going into the account? "FBO" is not a formal account designation. If the defendant is the representative payee of the dependent, the account should be titled:

• “(Beneficiary’s name) by (your name), representative payee.”

or

• “(Your name), representative payee for (beneficiary’s name).”

Likely I would be sitting down with legal counsel to figure out what is going on and what your responsibility might as far as the subpoena.

Like Randy said, this is probably a Rep Payee, and in such case, the person who is the dependent is the "owner" and the other person is simply the user acting in a fiduciary capacity.
At my institution, we treat these like pseudo guardianship's (only applies to this account, and not the entire relationship however) and the ward may be exempt from CIP depending on your institutions policy, in which case that might be why the SSN is missing. Either that or the relationship preceded CIP and your old policy didn't require SSN for account owners at that time.

In a Rep Payee situation, the CIP regulations and FAQ indicate that the representative payee is the account owner for CIP purposes (he/she opens and controls the account), since the beneficial owner of the funds in the account doesn't have the capacity to open such an account.