Ameriprise

They require an Inherited IRA. Although as of September 15, one charity was able to avoid sending in the personal information but still had to set up an Inherited IRA.  They used Charles Schultz’s “A” letter and had a phone call the next day from Ameriprise.  This is the person the charity worked with:   Heather Hanson and her direct line is (612) 671-3064.  However, RIFT is still pushing the removal of having to set up an Inherited IRA Account.

Send Charles Schultz “A” letter and address it directly to the following:
Karen Wilson Thissen
Executive Vice President and General Counsel
Ameriprise Financial
70100 Ameriprise Financial Center
Minneapolis, MN 55474

 

BNY Mellon/Pershing:

They do not require that a charity set up an inherited IRA.

 

Charles Schwab

They will -- on an exception basis -- allow a charity to receive the IRA death proceeds without setting up an Inherited IRA Account.

1. Send the Charles Schultz “B” letter to:
The Charles Schwab Corporation, 2
11 Main Street
San Francisco, CA 94105.
Attn:  David R. Garfield, General Counsel, Executive Vice President & Corporate Secretary

2. Submit a W-9

3. Submit a corporate resolution

4. Important! Copy the following 2 people on your letter:
Jerri L. Gibbs
Managing Director
Sales & Service Client Solutions
Schwab Advisor Services
Office:  407-806-6551
Cell: 407-865-2692
1958 Summit Park Dr.
Orlando, FL 32810

Tim Majewski
Sr. Specialist, Risk Analysis
Operational Services Estate Distribution Services
8332 Woodfield Crossing
Indianapolis, IN 46240
888-297-0244 Ext. 70197
Fax 888-857-7711

 

Edward Jones

They will -- on an exception basis -- allow a charity to receive the IRA death proceeds without setting up an Inherited IRA Account.

Send Charles Schultz “B” letter and address it directly to the CEO (not as a copy to him):
Christopher Lewis, Edward Jones General Counsel
12555 Manchester Road
St. Louis, MO 63131

Charities say they have received their check from Edward Jones within 30 days.

One charity recently said, “The only form we ultimately completed in order to receive the distribution was their "IRA Distribution Form" (which just asked for our wire instructions and tax withholding preferences) along with a Certificate of Incumbency demonstrating that our CFO has signing authority. We refused to complete their Corporate Resolution.”

Yet another nonprofit said: “We were told that we have to open a separate account to inherit an IRA share if we are one of many named beneficiaries. If we are the only named beneficiary, then they would close the account and send the distribution.  She also stated that they are working on updating the entire process so that we would not have to do this in the future."

Therefore, keep sending the Charles Schultz letter. 

 

Fidelity

They require an Inherited IRA.

Send Charles Schultz “A” letter and address it directly to the following:
Jonathan Chiel
General Counsel and Executive Vice President
Fidelity Investments, Inc.
82 Devonshire Street
Boston, MA 02109

 

LPL Financial, LLC

They require an Inherited IRA.

Send Charles Schultz “A” letter and address it directly to the following:
LPL Financial, LLC
Michelle Oroschakoff
Chief Legal and Risk Officer
4707 Executive Drive
San Diego, CA 92121-3091

 

Merrill Lynch

According to feedback from nonprofits, Merrill Lynch has been easy to work with. 

They require the following forms: 

Here is the feedback from one nonprofit as to how to complete the form: “Merrill Lynch requested that we complete their beneficiary distribution forms with a signed Letter of Authorization and the Secretary’s Certification confirming the signing authority.

When completing the beneficiary distribution forms, Merrill pre-populated the majority of the information and asked for us to enter the following information:

Part 1: Beneficiary Information:
Enter organization’s information contact information
Enter the organization’s EIN number under the “Social Security Number” field
Leave DOB blank

Part 2: Original Account Owner’s Information
Enter donor’s account information

Part 3: One-Time Distribution Amount
For our one-time fixed amount distribution, we checked “Part of the account” and “cash only” with the correct amount in the open field

Part 4: Standing Letter Distributions
Leave blank

Part 5: Withholding Election
Check “Do not withhold federal income tax from my distribution.”

Part 6: Distribution Methods
Under “II. One Time Distribution Options ONLY,” check “(d) Mail check/securities to the alternate address noted below:” and insert correct mailing address

Part 7: Federal Funds Wire Transfer Instructions
Leave blank

Part 8: Automatic Liquidation
Leave blank

Part 9: Signature
Signed by an authorized individual”

 

Morgan Stanley

They do not require a separate Inherited IRA account be established.

They need the following forms:

They don’t need a corporate resolution.

They can typically process this in 10 days or so once they’ve received the appropriate paperwork.

 

Northern Trust

A colleague with Northern Trust says, if it's a Trusteed IRA, Northern Trust does not require the charity to open an inherited IRA to receive distribution from the IRA on the IRA owner's death.  In that case, Northern Trust would ask the charity to provide:
(i) a letter of direction (with transfer instructions),
(ii) evidence that the person giving the instructions has authority to act on behalf of the charity, and
(iii) Form W-9. 

This colleague also notes, however, that with custodial IRAs, there is a different procedure depending on whether the custodial IRA is held with Northern Trust's banking division or with their brokerage division. The banking division does not require the charity to open an inherited IRA, while the brokerage division does. The colleague believes this difference is due to the brokerage division out-sourcing tax reporting to a third party vendor.

 

RBC

They require an Inherited IRA.

Send Charles Schultz “A” letter and address it directly to the following:
Dan Torbenson, General Counsel
RBC Wealth Management
345 California Street, Suite 2800
San Francisco, CA 94104
415-445-8422

 

TD Ameritrade

They require an Inherited IRA.

Send Charles Schultz “A” letter and address it directly to the following:
Ellen Koplow, Executive VP, General Counsel, Secretary
TD Ameritrade
200 South 108th Avenue
Omaha, NE 68154

 

UBS

UBS may be confused on a corporate level about whether they require an Inherited IRA or not. Experience shows it basically depends on who at UBS you have communicated with.  However, UBS stated in an email on September 11, 2019 and again on September 26, 2019 that UBS does not require an inherited IRA. 

All you need to do is complete their “IRA Beneficiary Total Distribution Form” and provided a Certificate of Incumbency signed by your CFO on your letterhead. You can refuse to complete and sign the Corporate Resolution. The whole process, from notification to receiving the funds, took this one charity about 60 days.

The legal counsel at UBS affirmatively stated on multiple occasions that each branch controls the IRA death claim payment process and that their company policy is to NOT require an inherited IRA.  So charities may have to push back at the branch level and tell them they have a corporate-wide policy to not require the inherited IRA. Keep pushing back. If necessary at the branch level, encourage the branch staff to obtain the correct corporate policy from Tammy Bawnik, Managing Director of their Legacy Advisory Services.

Tammy Bawnik
Managing Director
Head, Legal Advisory Services
UBS Group AG
UBS Financial Services Inc.
1000 Harbor Blvd
Weehawken, NJ 07086
Phone (201) 352-3120  
Fax (201) 442-3247  
tammy.bawnik@ubs.com

 

US Bank

US Bank does not require a charity to open an inherited IRA if they're receiving a lump sum distribution from the deceased owner's IRA. US Bank would just need a W-9 from the charity and they will make the payment directly from the deceased owner's IRA to the charity.

 

Vanguard

They will – on an exception basis – allow a charity to receive the IRA death proceeds without setting up an Inherited IRA Account.

Send Charles Schultz’s “B” letter to:
Anne R. Robinson, General Counsel of The Vanguard Group, Inc. Managing Director of the office of General Counsel
100 Vanguard Blvd,
Malvern PA 19355

Send a copy of the letter to:
Josh Dutill
Senior Counsel
The Vanguard Group, Inc.
Ext. 12229
610-669-2229

State you want $0 withholding (they may want an official IRS election form)
Submit a W-9
Submit a copy of your IRS determination letter

In addition to the Charles Schultz's "B" letter, Vanguard wants:

a) a letter of instruction signed by an officer requesting a direct distribution, (the letter must include: decedent’s account number, last four of decedent’s SSN, identification of the specific assets to be sold, how the check should be made payable and where it should be sent, a confirmation that the officer signing the letter of instruction has authority to request securities transactions, and

b)  a recently certified internal document that identifies the authority of the signing officer

We’ve also been given this person’s name as a helpful individual if you run into issues with them: Chris Milano, direct contact is 610-669-5050.

Per October 17, 2019, email from the Senior Counsel at Vanguard:  “Further, we are reviewing the process to determine how charities may make an IRA claim without asking for an exception to the general IRA policy.”

 

Wells Fargo

As of Sept. 3, 2019, Wells Fargo says they automatically (without specifically asking for an exception) allow charities to receive their IRA proceeds without setting up an Inherited IRA.  Therefore, nonprofits should not need to send either Charles Schultz letter.

Contact, if needed:
Douglas R. Edwards, Interim General Counsel
Wells Fargo Headquarters
420 Montgomery Street
San Francisco, CA 94104
800-869-3557

As of October 2019, Wells Fargo needed an IRA Beneficiary Claim Form (check the box in Section 3 for a Lump Sum).  Need assistance?  Contact Malissa S. Welch, Senior Client Associate, 208-363-7639, Malissa.welch@wfadvisors.com