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CIP ID If Institution Is Corporate Fiduciary?

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Question: 
Does a corporate fiduciary (trust Dept) need any form of ID under CIP for testamentary trusts that they are opening as trustee. example: Jane Smith dies leaving a will and names the bank as trustee of the trust for the benefit of her grandchildren.
Answer: 

Answer by Sam Ott:
The new CIP rules require that a principal place of business, local office or other physical location and an identification number be obtained for a person other than an individual such as a corporation, partnership , or trust. See Section 103.121(b)(2)(i)(A)(3)(iii)page 80.

Section 103.121.(b)(2)(i)(A)(3)(iii)

You will also need to obtain the TIN for the trust.Since the grantor of the trust is deceased, I suggest you obtain the name and address of the administrator or executor of the estate who presents the court documents which provide that your trust department has been designated the corporate trustee.

Answer: 

Answer by Ken Golliher:

My suggestion is that a copy of the will (containing the trust) and a copy of the court order naming your bank as trustee (if required by state law) is plenty of verification. Most trust departments serving as fiduciaries already require enough information and verification to comply with CIP, but they may need to write it down in the form of specific procedures subject to board approval.

The beneficiaries are not "customers" under CIP, but you will need the information on them for K1 purposes.

First published on BankersOnline.com 06/2/03

First published on 06/02/2003

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