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CIP Requirements for Opening Acct. Under FLUTMA

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Question: 
My inquiry has to do with CIP requirements regarding opening an account under a FLUTMA (we are in Florida). The account holder which is the grandmother opened an account under a FLUTMA for the grandchild. The parents do not wish to release a copy of their child's birth certificate due to possible fears of compromise. Is it mandatory to require CIP information on the minor once the Chex Systems clearance has been obtained; is a birth certificate actually required?
Answer: 

Regardless of the state, under the CIP rule the custodian is acting on behalf of a person who is under a disability (age) and it is the custodian who is considered the customer for the purposes of CIP. It is the custodian's information you must verify, not the child's.

You need the child's name and SSN for the purposes of information reporting, nothing else. Requiring a birth certificate as documentation for a UTMA is outside my experience and, in my opinion, is totally unnecessary.

First published on 03/18/2018

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