[WSBAPT] Qualified Account Distribution Problem with 501(c)(3) beneficiary

[Heather deVrieze]

Looking for a solution to the problem presented below:

Has anyone confronted the problem recently caused when the Department of the Treasury issued a rule under 31 CFR 1020.230 requiring Financial Institutions to obtain social security numbers from Key Control Persons of all entities, including major 501C(3) organizations before creating accounts?  I am having a problem with a stock broker acting under a beneficiary designation account who refuses to set up an account for The Nature Conservancy because that organization refuses to provide Name, Address, Title, Date of Birth, SSN for any person acting as a Key Control Person.  That refusal is causing problems for the other beneficiaries of the IRA because the stock broker wants 100% agreement of all beneficiaries before distributing the funds into separate inherited IRAs.  The rule took effect in May 2018.  There appears to be no exception for the size of the organization.

Any thoughts on how to push back on this broker's requirement, or does the employee of The Nature Conservancy have no choice but to provide their SSN to the broker?

Heather

Heather S. de Vrieze
Attorney-at-Law
[cid:image001.jpg at 01D013C2.30F35160]
3909 California Avenue SW
Seattle, WA 98116-3705
(206)938-5500
heatherd at westseattlelaw.com<mailto:heatherd at westseattlelaw.com>
www.westseattlelaw.com<http://www.westseattlelaw.com/>

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