Academic journal article ABA Banking Journal

Custodial Accounts and Reg DD

Academic journal article ABA Banking Journal

Custodial Accounts and Reg DD

Article excerpt

Q. I have read that custodial accounts are not covered under Regulation DD and that no Regulation DD notice is required. I have an account where a separate legal entity (a custodian) is the actual account owner. We have the taxpayer identification number (TIN) of the custodian associated with the account and the custodian is the sole signer 0f the deposit account. The account houses funds from individuals who do not hove signing authority and who are not listed as the account holder. In addition, no individual has their TIN associated with the account. Given this scenario, are we required under Regulation DD to provide o disclosure to the custodian? The individual? Both? No one?

A. The scenario you describe would not be considered an "account for Regulation DD purposes. If you look at the definition of "consumer," the regulation states that:

"Consumer means a natural person who holds an account primarily for personal, family, or household purposes, or to whom such an account is offered. …

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