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Who to CIP on a Trust

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Question: 
If we have a revocable living trust, and the Grantor and Trustee are different, would we CIP both the Trustee and Grantor, or just the Trustee?
Answer: 

You should follow you board approved CIP. The trust is your customer according to the CIP regulation. If your internal extends CIP requirements to signers, trustees, etc. then you must follow your institution's CIP.

First published on 09/03/2023

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