Can anyone direct me to a thread that has addressed what information will be gathered when an attorney opens an estate account? I feel that the attorney is the "person" opening the account and that we will have to collect his/her name, address, dob and TIN. This is completely separate from how that account will be set up, but seems to follow the logic of CIP. Any comments? Thanks

Check state law on whether an estate is a legal entity. If it is, then the estate is the customer.

Previously existing BSA regulations define what is a "person:"

31CFR103.11(z) Person. An individual, a corporation, a partnership, a trust or estate...

The estate is the customer. It is the estate whose information you must obtain and whose identity you must verify. A copy of the court order appointing the personal representative (may or may not be an attorney) is your principal source of verification.

I agree with Ken. Your letters from the court appointing the personal representative to/for the estate with be the documentation necessary for CIP purposes to open the account.