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CIP on Estate Accounts

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Question: 
For purposes of setting up an estate account, who is considered the customer for purposes of CIP?
Answer: 

The term "estate" is used most often to refer to the property of a deceased individual. In that sense, the estate is a "person" under the law, and the estate (represented by the executor, administrator, or other personal representative approved and appointed by the court), is the customer.

When the estate is property of a live individual (such as the estate of a minor or incapacitated individual), your customer for CIP purposes is the individual appointed as the conservator or guardian by the court (the minor or incapacitated individual doesn't have the legal capacity to open the account). The TIN needed for IRS reporting purposes is the SSN of the individual who actually owns the property.

First published on BankersOnline.com 3/29/10

First published on 03/29/2010

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