We have a legal entity that does rep payee services for individuals. The account is opened using the individual name and SSN and listed at the owner and the legal entity is the payee. I believe these accounts would be exempt since the legal entity is not the owner.

Thoughts?

Your customer is the legal entity. While the beneficiary of the SSA or SSI payments has a legal claim to the funds in the account, the legal entity owns the account and is accountable to both the Social Security Administration and the beneficiary for the use of those funds.

For the purpose of the Beneficial Ownership rules, you treat such an account just like any other account of the legal entity.

Thanks!