No, the CIP rules do not require you to update the account information for this account, but it may be prudent to obtain additional information to confirm the accountholder’s “true identity,” which in this case would include obtaining information about the trustees for the trust.

The CIP rules permit banks to grandfather certain accounts opened before the rules became effective on October 1, 2003. A bank is not required to collect the information required by the CIP rules for grandfathered accounts, provided that the bank has a “reasonable belief that it knows the true identity” of the accountholders.

Here, given that the authorized signers are not identified as the trustees, we believe it would be prudent to obtain additional information to confirm that the signatories are the trustees of the trust for which the account was opened. As suggested in the FFIEC’s BSA/AML Examination Manual, for an account held by a trust, confirming the accountholder’s “true identity” may require gathering information about the account’s signatories and trustees. In addition, with respect to trust accounts, it is always advisable to confirm the identity and powers of the trustees in order to ensure that the account is authorized by the trust instrument.

For resources related to our guidance, please see below:

• CIP regulations, 31 CFR 1020.100 (“customer” excludes a person that has an existing account with the bank, provided that the bank has a “reasonable belief that it knows the true identity of the person”)
• CIP regulations, 31 CFR 1020.220(a)(2)(i) (CIP rules require name, address, and tax ID number for a trust)
• FFIEC’s BSA/AML Examination Manual on Trust and Asset Management Services—Overview (“For example, in certain circumstances involving revocable trusts, the bank may need to gather information about the settlor, grantor, trustee, or other persons with the authority to direct the trustee, and who thus have authority or control over the account, in order to establish the true identity of the customer.”)