02/21/2011
In Florida, when a minor's account is opened, is the account reported under the minor's social security number or the adult's? This is not a FUTMA account, only a minor's savings account.
10/04/2010
In the past, we have allowed grandparents to open savings accounts for their grandchildren with the grandchildren being the primary owners and the grandparents as secondary. They would have the child's social security number. They would sign the child's name,(child is unable to sign due to age). Relative to CIP purposes can this still be done?
06/14/2010
We have a parent who opened three custodian accounts for his minor children. We have SSNs for all of the minors. When we try to fill in the CTR, we can't get past Section B, line 25. It's asking for item F to be completed. Do we need to add the children as benefactors, and if so, what can I put on line 25 in order to complete the CTR?
07/26/2009
Who is the customer when an account is opened by a power-of-attorney. I have read over the answer to the question posted under CIP titled <a href="http://www.bankersonline.com/security/guru2008/gurus_sec022508c.html">"POA CIP Requirements"</a>, and also Section 103.121(a) (3) Q and A outlined in the regulation. What is the definition of "legal capacity"? I am in the process of updating the CIP section of our Anti-Money Laundering Policy and I need to address this issue. A POA comes in and opens a checking account for an individual that is incarcerated. The POA document provides for the POA to open accounts for that person. Since the individual is in jail, does he or she lack legal capacity?
01/12/2009
Is CIP documentation required for court ordered accounts such as when minor children receive money from a sale of property and the court orders CDs to be purchased for the minors and held until they are 18 years old?
09/08/2008
I have a customer that opened three accounts, one for each of her children as they receive Social Security direct deposit benefits. The mother is the signer on each account and the individual child was added as an owner only because they are only nine, eleven and seventeen years of age. The mother wants debit cards in the children’s names so she can keep the account straight as to where she is pulling the money from. Can we issue debit cards to a minor and if so, would the mother have the legal right to use them? How would it be handled if the child’s card was used and they wanted to dispute the transaction?
06/05/2006
If a minor account is opened using the child's social security, titled beneficiary (the minor) by custodian, what happens to the funds if the custodian passes away?
05/01/2006
This question is in regard to OFAC. Is there any stipulation when opening a new account (new customer(s)) that contains a minor, that you should not have to worry about checking a minor against the SDN list? Let's say you open Jr. Savings Accounts, what should be the bank's policy and procedures for checking the SDN list at account opening?
01/02/2006
At what age must we do CIP on a person if they are a minor or is it required? We require all minor accounts to have someone over 18 as a signer and do CIP on them. For instance, if a parent opens a savings account for a 10-year-old child, are we required to do CIP on the child? At what age is a child considered legally competent?
07/18/2005
When a parent opens an account for a minor and uses the minor's Social Security number, but only the parent signs on the account, is the ownership of the account joint or individual?