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Patriot Act - Qualified plan - Brokerage Account - Trustee SSN?


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Have a 401k PSP where the doctors have investments in different brokerage firms (Schwab, Fidelity, etc.). This plan recently voted to update their trustee listing to incorporate all 12 current owners. An advisor for another doctor at the company advised the plan sponsor that all 12 trustees must report their SSN and DOB to Fidelity (custodian of doctor's assets) due to the Patriot Act. 

I tried researching the Patriot Act and did not have any luck. Is the advisor correct?

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A bank or broker-dealer might be correct in asking for information on all trustees.  Further, even if you might learn the banking and securities laws and rules involved and might find that a particular bank or broker-dealer asks for more information than the minimum public law requires, knowing that information likely wouldn’t help.  In applying know-your-customer and anti-money-laundering laws and rules, each bank or broker-dealer designs its own policies and procedures.  A procedure might require obtaining information about each human who has some authority or control over the account to be opened or continued.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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