Social Security Number for Guardianship Account

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Question:

Recently, our New Accounts has opened a few Guardianship Accounts. They have the proper documentation but we believe that the accounts may be under the incorrect social security number. What social security number should the account be filed under? Is it the Guardian (representative) or the Guardianship (beneficiary)?

Answer:

There are two questions involved in these scenarios. First, there is the question of who is your customer for CIP purposes? The customer in such cases is the guardian, because the ward does not have the capacity to open the account. So you must obtain the guardian's SSN (U.S. persons) as part of the CIP process.

The second question is which SSN should you use for tax reporting purposes? Put in another way, which SSN should you assign to the account under a CIF-type system? The funds are beneficially owned by the ward; the guardian is acting as a fiduciary. So the SSN you obtain and assign to the account for tax reporting and CIF purposes should be that of the ward.

First published on BankersOnline.com 9/26/11