RSK.IQ Question of the Week 11/14/16

Title for SSA Representative Payee Account


One of the Bank’s customers is an assisted living facility which has asked to open 60 “representative payee” accounts on behalf of clients living at the facility. How should such accounts be titled? What information should the Bank gather for account opening?

Response Summary

The title of the account must establish the beneficiary ownership of the funds. The Bank should follow its customary Customer Identification Program (“CIP”) process in opening the account.

Response Detail

The Bank should obtain evidence that the Social Security Administration has, in fact, approved the Assisted Living Facility as a representative payee for each of the named payees.

In addition, the Bank will need to complete its CIP process with the representative payee as its customer, but ensure that the beneficiary's Social Security number is used for the Customer Information File and interest reporting systems, and not that of the representative payee.

The beneficiary must not have direct access to the account or sub account. A separate account or sub account is mandatory for each beneficiary. Since each sub account is a separate account, payments for beneficiaries with representative payees may be direct deposited to the same master account as those of other beneficiaries.

Any form of account title the Bank recognizes as establishing beneficiary ownership of the funds, but without beneficiary direct access to them, is acceptable. The title of the account or sub account must show that the representative payee has only a fiduciary interest in the funds.

As examples of master account titles for nursing homes, the Social Security Administration offers the following:

  • Sunnydale Nursing Home Resident Trust Account
  • Sunnydale Patient’s Fund for Social Security Beneficiaries

Please also see Social Security Administration, Program Operations Manual, GN 02402.055 and Social Security Administration “A Guide for Representative Payees.”

This entry was posted on Monday, November 14th, 2016 at 1:34 pm.

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