CIP on an Irrevocable Trust

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Question:

If an irrevocable trust is set up whom do we CIP, the trustees, the beneficiaries?

Answer:

At a minimum, the CIP regulation 31 CFR 103.121 requires that you obtain and verify identification information on the trust, remembering that an irrevocable trust is required to have its own TIN. I imagine that virtually every bank's CIP would also require that ID information be obtained and verified on the trustee(s).

The beneficiaries are definitely not customers for CIP purposes. It's therefore not necessary to get ID information on the beneficiary or beneficiaries unless your bank's CIP calls for it.

First published on BankersOnline.com 8/17/09