Answer:
It could cause the primary signer -- and your bank -- a lot of aggravation. You should never use an individual's SSN as the TIN for accounts that are not in the signer's own name, with the exception of certain single-member LLCs and grantor trusts. Even in those few cases, you have to make sure that the name sent to the IRS matches the SSN at year-end if any 1099s are generated. Using the signer's SSN for CIP purposes is appropriate, since the memorial fund isn't a legal entity itself, but the bank should insist that a TIN be applied for so that year-end reporting can go smoothly.
First published on BankersOnline.com 4/03/06