We are not aware of any law that prohibits trusts or business entities from leasing a safe deposit box. However, we note that safe deposit boxes are subject to Customer Identification Program (CIP) regulations, which require you to collect (at a minimum) the name, address and social security or other tax identification number of every customer.

As part of your CIP, you also must verify the existence of the business or trust through documentary or non-documentary methods. Documentary methods may include reviewing certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. Non-documentary methods of verification may include comparing the customer’s information with a public database (like the Secretary of State website), checking references with other financial institutions, and reviewing a financial statement.

For resources related to our guidance, please see:

• FinCEN Rules for Banks, 31 CFR 1020.220(a)(2) (CIP requirements)

• FinCEN Rules for Banks, 31 CFR 1020.100 (“Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.”)