Answer:
At minimum, you must consider the trust as your customer, and obtain the required three items of identification (name, street address and identifying number), and verify the trust's identity (existence) to your satisfaction. In addition, it's likely that your institution's CIP accounts for the fact that trusts are easily created and easily faked by requiring that the individuals opening the account -- the trustee(s) in this case be identified as if they were the customers. The beneficiary is not a customer for CIP unless by coincidence he or she is also a trustee, and the grantor, who you said is dead, obviously cannot be your customer and his or her former identity is irrelevant.
First published on BankersOnline.com 4/27/09
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