Transferring of Accounts (Beneficiary & IRA)

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Question:

The majority of our IRA customers have their spouse listed as beneficiary. When an IRA holder passed away, we would change the title to the "Spouse as Beneficiary of the deceased IRA" and their SS# if they chose to not treat as their own. We had two IRA holders (in RMD) pass away this year and had multiple children listed as beneficiary. We set up separate accounts for each child as "Beneficiary of the fathers IRA" and transferred the funds to them. This was done "in-house" with transcodes to just transfer the funds to the separate accounts (no paper work other than the entries). What is the proper way to handle the transferring of accounts like this? Should we have completed new account paperwork for a new IRA account? For CIP purpose?

Answer:

Do not be so lazy as to file maintenance the ownership of an IRA to the name of another person, even a surviving spouse who is entitled to treat the IRA as his or her own. Have the surviving spouse execute an IRA agreement and a beneficiary designation. Transfer the funds from to account of the decedent to that of the surviving spouse. (The transfer is not reportable.)

There are no IRS rules, guidelines, suggestions, nothing on the mechanics on how to handle payments to nonspouse beneficiaries. If a decedent's IRA is paid to a beneficiary, all the IRS wants is a 1099R with the beneficiary's name, address, and SSN with a distribution code of "4" or "distribution due to death whenever those payments are actually made.

Your mechanism, establishing a "payout" account for each beneficiary, satisfies that goal. It is also the one most banks use because it automatically generates all necessary information reporting. Make a non reportable transfer of the decedent's funds to the payout account of the beneficiary as instructed.

A POD beneficiary is not opening an IRA. They do not need to execute an IRA agreement. However, they are opening an account, even though the account may be closed the same day (a full distribution is made). You should apply your CIP. Unless the account is to be opened and closed the same day, the beneficiary should designate a beneficiary for the payout account.