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Are we required to obtain the social security number of a beneficiary on a payable on death (POD) account? – IBA Compliance Connection

IBA Compliance Connection

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Are we required to obtain the social security number of a beneficiary on a payable on death (POD) account?

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No, you are not required to obtain the social security number of a POD beneficiary.

Under the Customer Identification Program (CIP) regulations, your CIP procedures must, at a minimum, include obtaining and verifying certain identifying information about a customer, including the customer’s taxpayer identification number. However, since the CIP regulations define a “customer” as a “person who opens a new account,” this requirement would not extend to POD beneficiaries.

For resources related to our guidance, please see:

  • FinCEN CIP Regulations, 31 CFR 1020.220(a)(2)(i) (“The CIP must contain procedures for opening an account that specify the identifying information that will be obtained from each customer. Except as permitted by paragraphs (a)(2)(i)(B) and (C) of this section, 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 . . .; and (4) Identification number. . .”)
  • FinCEN CIP Regulations, 31 CFR 1020.100(c)(1) (“Customer. For the purposes of § 1020.220: (1) Customer means: (i) A person that opens a new account; and (ii) An individual who opens a new account for: (A) An individual who lacks legal capacity, such as a minor; or (B) An entity that is not a legal person, such as a civic club.”)