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#2214605 - 05/30/19 03:33 PM Funeral or Burial Trust Accounts
Margarita Offline
Member
Joined: Oct 2005
Posts: 72
Wisconsin
When opening a funeral trust account, how do you title the account if the funeral home is the one opening the account and signing the signature card? Do you put the account under the person or the potential decedent's SSN or the funeral home's EIN? And finally, who do you CIP - both the person and the funeral home or just whoever is opening the account and signing the signature card? Sorry for all the questions but we are going round and round over this subject.

Any feedback would be greatly appreciated!

Thank You!

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#2236725 - 05/14/20 09:12 PM Re: Funeral or Burial Trust Accounts Margarita
BJ Blazko Offline
New Poster
Joined: Apr 2016
Posts: 20
I'm wondering about this too. did you ever get any guidance on this?

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#2236729 - 05/14/20 10:11 PM Re: Funeral or Burial Trust Accounts Margarita
Margarita Offline
Member
Joined: Oct 2005
Posts: 72
Wisconsin
No I did not. When I ran this past one of our attorneys, he stated we shouldn't allow the funeral home to open the account and that the potential decedent should be the one to open the account. That is why I was asking what other banks are doing.

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#2257737 - 08/05/21 05:52 PM Re: Funeral or Burial Trust Accounts Margarita
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,236
Wisconsin
Bringing this back to life. Does anyone in WI deal with funeral trusts? Our new BSA Officer is questioning these and how CIP is impacted.

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#2257742 - 08/05/21 06:51 PM Re: Funeral or Burial Trust Accounts Margarita
Margarita Offline
Member
Joined: Oct 2005
Posts: 72
Wisconsin
Yes, we deal with funeral trust accounts all the time and have for years and this is what we have decided to do. Sometimes the funeral trust account is opened by the "potential decedent" and sometimes it is opened by the funeral home director. Either way, getting the signed funeral trust agreement is what governs everything.

As to CIP, if the potential decedent opens the account, we CIP them and they sign the signature card. Since the funeral home is only the beneficiary of the funds, we would not CIP them until they come in to collect the funds for services provided.

Though as I stated above about the advice from our attorney on not letting the funeral home director open the funeral trust account, our bank has decided this is a low risk and allows it. If the funeral home director comes in to open the account on behalf of the potential decedent, we CIP the potential decedent and we CIP the funeral home - including Beneficial Ownership. The Ownership portion would not be completed but you would complete the Control Prong. This was verified with FinCEN.

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