When opening any type of deposit account, you should follow your standard deposit account opening procedures, which, in the case of a trust, should include obtaining certain information about the trust and its trustees (and, in some high risk circumstances, also about the trust’s beneficiaries).

The IRS requires the taxpayer identification number (TIN) used for Miller Trusts (also known as “qualifying income trusts” or “supplemental needs trusts”) to be either the trustee’s social security number or the beneficiary’s social security. Other than that, we are not aware of any unique tracking or compliance requirements on the part of a bank when offering deposit accounts for Miller Trusts.

For resources related to our guidance, please see:

• IRS, Internal Revenue Manual, Part 21.7.13, Assigning Employer Identification Numbers (EINs), Determining the Need for an EIN: Trusts (“[If] the trust is a Miller type trust: Do not assign an EIN. Instead, inform the trustee that he/she must: (1) Use the SSN of the beneficiary or trustee to report trust activities, and (2) Provide information such as the SSN, BOD, closing month of accounting year, principal activity, and the market to which they sell their product or services, if not already provided on Form SS-4 under Treasury Regulation 301.6109-1(d)(2). Note: Miller Trusts are treated as grantor trusts under IRC § 671.”)