CIP on a Beneficiary

Assuming that your question concerns the beneficiary of a Totten trust (“in trust for”) or Pay on Death (“POD”) beneficiary, the only beneficiary info required for CIP is whatever your bank’s policy calls for. Under the CIP regulations at 31 CFR Part 103, Section 103.121, the beneficiary is not a customer for the purposes of CIP; the account owner is.

That said, the bank’s other procedures (non-CIP) may dictate that you obtain additional information on the beneficiary to assist in verifying identity and making contact should the account owner die with the beneficiary designation still in effect.

First published on BankersOnline.com 4/4/11