FinCEN (Financial Crimes Enforcement Network) today (Fri) published an administrative ruling today regarding customer identification program (CIP) and CDD requirements for designated beneficiaries of individual retirement accounts (IRAs).
The request asked whether a broker-dealer must comply with certain requirements of the CIP and CDD rules when distributing to a beneficiary of an IRA funds inherited as part of a charitable estate.
FinCEN’s response affirms that to the extent that the broker-dealer requires the opening of an account, FinCEN’s regulations would require the broker-dealer to collect certain information under the CIP and CDD rules.
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