Answer:
If by "Patriot Act Form" you mean a form on which you collect and verify identity information under your bank's Customer Identification Program, you must collect identifying information and verify the identity of your "customer." Under the regulations, your customer when opening an account for a living trust is the trust, not the trustees or grantors, so you have to collect information on the trust. Your bank's CIP, however, undoubtedly instructs you to collect information on the individual trustees of the trust, and you must do so in order not to have a policy violation.
First published on BankersOnline.com 5/04/09
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