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Requirement to Verify a Beneficiary

Question: 
Are there any specific requirements that we verify that a beneficiary is a natural person, charitable organization, or other non-profit entity for purposes of complying with 12 CFR 745.4(c)&(d) - beneficiary of a trust?
Answer: 

by John Burnett:

No. Clearly, there is an advantage to having accurate information on the beneficiary, including their SSN or EIN, for example, and DOB for individuals -- to be able to ensure you'll be handing the funds over to the right person(s) or entities, when the time comes, but there's nothing in the regulations that you verify the bona fides of the beneficiaries. That's true for the rule you cited relating to deposit insurance for credit union members and depositors, and for the FDIC's similar rule covering deposits in banks and savings associations.

Answer: 

by Randy Carey:

John, technically the bank would not be handing over anything to the beneficiaries of a trust, as that would be up to the trustee or successor trustee. But for FDIC insurance purposes, they should be identified.

First published on 04/23/2023

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