How about where the FI cannot tell when the Trustor/Settlor passes away. Is it best practice to document each discretionary beneficiary, as it’s very uncommon for an account holder to divulge such information that would require additional documentation?
The FI will have to continue to name the Trustor/Settlor as the account holder until they have information to demonstrate that the Trustor/Settlor has died. The discretionary beneficiaries cannot be listed until they become account holders (i.e. until they have received the distribution). The RFI must use reasonable efforts to ensure that the information they