We believe that your customer’s class reunion account can be titled either in the name of the individual(s) who own the funds or in the name of an unincorporated association (that is, an organization formed for a noncommercial purpose with deposits separate from those of the members comprising the association).  

While deposit insurance may not be a concern for a class reunion account, the deposit insurance rules provide helpful guidance for account titling. If the account is titled in the name of an individual owner, it likely will be insured as the personal funds of that individual and not as the funds of the organization. But if the account is titled in the name of an unincorporated association, it likely will be insured separately from the personal funds of the officers or members. To avoid any ambiguity, if you intend to title the account in the name of an unincorporated association, we do not recommend including an individual’s name in the account title.

Whether the account is an individual or unincorporated association account, your bank must obtain a taxpayer identification number (TIN) as part of your Customer Identification Program, but an EIN is not required. If the customer is opening the account titled in the name of an unincorporated association, we believe the individual opening the account could either provide their social security number or obtain an EIN from the IRS. If the account will accrue interest, your customer may wish to obtain an EIN (for example, by applying as a “social club” in the IRS EIN application) so that your bank is not required to report interest under an individual owner’s social security number.

For resources related to our guidance, please see:

• 12 CFR 330.5(a)(1) (“[[i][/i]I]n determining the amount of insurance available to each depositor, the FDIC shall presume that deposited funds are actually owned in the manner indicated on the deposit account records of the insured depository institution. If the FDIC, in its sole discretion, determines that the deposit account records of the insured depository institution are clear and unambiguous, those records shall be considered binding on the depositor, and the FDIC shall consider no other records on the manner in which the funds are owned. If the deposit account records are ambiguous or unclear on the manner in which the funds are owned, then the FDIC may, in its sole discretion, consider evidence other than the deposit account records of the insured depository institution for the purpose of establishing the manner in which the funds are owned. . . .”)

• 12 CFR 330.6(a) (“Funds owned by a natural person and deposited in one or more deposit accounts in his or her own name shall be added together and insured up to the SMDIA in the aggregate. . . .”)

• Financial Institution Employee’s Guide to Deposit Insurance (Single Accounts) (“Individually owned accounts are accounts owned by natural persons (i.e., human beings). The most common single account is a deposit account opened by an individual on his or her own behalf. The depositor maintains the account and owns the funds on deposit. These accounts are simply titled in the owner’s name, such as ‘John Smith.’”)

• 12 CFR 330.11(c) (“The deposit accounts of an unincorporated association engaged in any independent activity shall be added together and insured up to the SMDIA in the aggregate, separately from the accounts of the person(s) or entity(ies) comprising the unincorporated association. An unincorporated association shall be deemed to exist, for purposes of this paragraph, whenever there is an association of two or more persons formed for some religious, educational, charitable, social or other noncommercial purpose.”)

• Financial Institution Employee’s Guide to Deposit Insurance (Corporation, Partnership and Unincorporated Association Accounts) (“Deposit accounts held in the name of an unincorporated association (such as a neighborhood association or a scout troop) engaged in an independent activity are insured as the association’s deposits, separately from the personal deposits of the officers or members. In order for the account to receive separate coverage, the title of the account must include the name of the unincorporated association. In other words, if the accounts are titled using the names of the officers of the organization, the accounts may be insured as the personal deposits of the individuals and not as the funds of the organization. Insurance coverage for deposits held by an unincorporated association is a maximum of $250,000. The number of signatories on the account or the number of members that the association may have does not affect the amount of insurance coverage.”)

• 31 CFR 1020.220(a)(2) (“Customer Identification Program: minimum requirements . . . . (2)(i)(A) In general. . . . the bank must obtain, at a minimum, the following information from the customer prior to opening an account: (1) Name; (2) Date of birth, for an individual; (3) Address, which shall be: (i) For an individual, a residential or business street address . . . (iii) For a person other than an individual (such as a corporation, partnership, or trust), a principal place of business, local office, or other physical location; and (4) Identification number, which shall be: (i) For a U.S. person, a taxpayer identification number