Ameriprise

Ameriprise requires an Inherited IRA. Although as of September 15, 2020, 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.  However, RIFT is still pushing the removal of having to set up an Inherited IRA Account, as permanent policy. 

Another charity had success working with the following person:
Joe Van Eschen
Senior Settlement Specialist
Life Events
Ameriprise Financial
2110 Ameriprise Financial Center Routing S08/2110
Minneapolis, MN. 55474
Joe.x.vaneschen@ampf.com

Send Hays IRA 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

Note there is a suggested attachment to the letter. Also, we have had success with other custodians when a nonprofit copies their state’s attorney general on the letter and the state of the deceased donor. Get the name and address of your state’s attorney general.

 

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Ameriprise require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

 

BNY Mellon/Pershing:

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

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by BNY Mellon/Pershing require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

Charles Schwab

Schwab will – only on an exception basis -- allow a charity to receive the IRA death proceeds without setting up an Inherited IRA Account. Otherwise, you will receive all the paperwork to set up an Inherited IRA Account.

1. In order to obtain the necessary exception, the nonprofit must send the Charles Schultz “B” letter to:
The Charles Schwab Corporation
211 Main Street
San Francisco, CA 94105.
Attn:  Peter J. Morgan, III, Executive Vice President, General Counsel and Corporate Secretary

2. Submit a W-9

3. Submit a corporate resolution (click here for a sample resolution)

4. Important! Copy the following person on your letter:
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

 

One nonprofits experience: “Our nonprofit was notified about a Schwab IRA distribution and asked to open a new Inherited IRA account. (They didn’t know about the RIFT exception letter.) Asking the account manager was not helpful, as they did not know how to transfer the funds without first transferring them to a different account, but they did refer me to the division of Schwab that handles estate gifts. I sent the RIFT exception letter and had a response within days and although they asked me to change the letter of instruction's signature to one of our authorized signers for brokerage account transactions and attach a corporate resolution, it went through within a few days. I also wanted to add, the folks I dealt with at Schwab were very pleasant throughout the process.”

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Charles Schwab require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

Edward Jones

Edward Jones no longer requires charities send an “exception” letter to bypass their inherited IRA process. In fact as of July 2022, charities do not need to open a new account to get paid on a beneficiary claim.  They now have one claim form for the charity to complete for IRA accounts and a different claim form for after-tax (TOD) accounts.

Send:

  1. Edward Jones claim form
  2. IRS form W-9
  3. Your corporate resolution

The claim form and W-9 form which are signed by someone named in the corporate resolution can be mailed, emailed or faxed (along with the corporate resolution) to the local Edward Jones office.  The local office should provide the email or fax number for the documents to be sent to them.

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Edward Jones require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

Fidelity

Fidelity requires an Inherited IRA. There have only been two exceptions that the RIFT project is aware of since 2018.  All other charities have received letters in response to Charles Schultz’s “A” letter denying our position and continuing to require an Inherited IRA.

Therefore, RIFT so use this letter “Hays IRA Letter” to continue to push back.  Note there is a suggested attachment to the letter. Also, we have had success when a nonprofit copies their state’s attorney general on the letter. Get the name and address of your state’s attorney general.

Address the letter to the following:
Jonathan Chiel
General Counsel and Executive Vice President
Fidelity Investments, Inc.
82 Devonshire Street
Boston, MA 02109

One charity that was successful, worked with their state’s attorney general, board chair, and this attorney at Fidelity: 
Michele Darby, Legal Counsel
(817) 474 - 9962
michele.darby@fmr.com
1 Destiny Way, #WA1L
Westlake, TX 76262 

The other charity was the sole beneficiary of the IRA and no sale of assets were needed to liquidate the account because it was all invested in cash at the time of death. 

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Fidelity require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

LPL Financial, LLC

LPL Financial, LLC requires an Inherited IRA.

To attempt to push back against opening an Inherited IRA, send Hays IRA Letter and address it directly to the following:

Note there is a suggested attachment to the letter. Also, we have had success with other custodians when a nonprofit copies their state’s attorney general on the letter and the state of the deceased donor. Get the name and address of your state’s attorney general.

LPL Financial, LLC
Michelle Oroschakoff
Chief Legal and Risk Officer
4707 Executive Drive
San Diego, CA 92121-3091

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by LPL Financial require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

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”

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Merrill Lynch require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

Morgan Stanley

Morgan Stanley does not require a separate Inherited IRA account be established.

They need the following forms:

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

For non-tax qualified TOD (Transfer on Death Accounts)

TOD accounts held by Morgan Stanley require a new account to be opened first – prior to being paid on a donor’s TOD account. It is unclear why IRAs do not require a new account but TOD accounts do.

Although the RIFT project originally began as an IRA issue, many nonprofits have let us know they are having trouble receiving death benefits when their donors have made the charity a beneficiary of an after-tax account - often referred to a TOD (Transfer On Death) account. These accounts are invested with after-tax dollar and are not pre-tax accounts like IRAs, 401(k)s, 403(b)s, etc. Now, the RIFT project has an after-tax account sample letter for charities to use and customize to meet their own situation.

TOD sample letter. Note there is a suggested attachment to the letter. Also, we have had success when nonprofits copy their state's attorney general on the letter. Get the name address of your state's attorney general.

 

Northern Trust

Trusteed IRA: 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. 

Custodial IRA: 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.

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Northern Trust require a new account to be opened first, prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

Raymond James

One nonprofit has indicated that Raymond James did not require them to open up an Inherited IRA but instead received a direct distribution.  The nonprofit completed:

  1. Raymond James Beneficiary Request Form requesting a lump sum complete distribution 

  2. Provided a corporate resolution

 

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has been informed that TOD accounts held by Raymond James require a new account to be opened first, prior to being paid on a donor’s TOD account.

 

Although the RIFT project originally began as an IRA issue, many nonprofits have let us know they are having trouble receiving death benefits when their donors have made the charity a beneficiary of an after-tax account - often referred to a TOD (Transfer On Death) account. These accounts are invested with after-tax dollar and are not pre-tax accounts like IRAs, 401(k)s, 403(b)s, etc. Now, the RIFT project has an after-tax account sample letter for charities to use and customize to meet their own situation.

TOD sample letter. Note there is a suggested attachment to the letter. Also, we have had success when nonprofits copy their state's attorney general on the letter. Get the name address of your state's attorney general.

 

RBC

RBC requires an Inherited IRA.

To push back, send Hays IRA 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

Note there is a suggested attachment to the letter. Also, we have had success with other custodians when a nonprofit copies their state’s attorney general on the letter and the state of the deceased donor. Get the name and address of your state’s attorney general.

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by RBC require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

State Street Global Advisors 

RIFT does not have information on how IRAs are handled.

For non-tax qualified TOD (Transfer on Death Accounts)

One nonprofit advised RIFT that they were granted an exception when they used the TOD sample letter to push back on a request for the personal information of their authorized signer for a TOD on a brokerage account at State Street Global Advisors. Once State Street Global Advisors reviewed the RIFT TOD letter, they granted an exception and the nonprofit had to complete a form with its authorized signer’s signature and a medallion guarantee.

 

Stifel Financial Corp

Send the Hays letter to their General Counsel

One nonprofit said they had the IRA gift in a very timely fashion after sending the RIFT letter.

Mark Philip Fisher
General Counsel
Stifel Financial Corp
1 Montgomery Steet, Suite 3700
San Francisco, CA 94104-5537
Telephone: (415) 364-2676 (no information if this is a general number or direct)

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Stifel Financial Corp require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

TD Ameritrade

Important: The procedures will vary based on what type of IRA TD Ameritrade calls your IRA:  Either Retail (A) or from TD Ameritrade Institutional (a division of TD Ameritrade) (B).

A. Retail Accounts (see below):
As of February 2020, TD Ameritrade does not require an inherited IRA to be established.

However, after much debate TD Ameritrade will not cut a check to the charity for the IRA proceeds, but it will transfer the assets inside the IRA to an account of the charity’s choice. The account does not have to be at TD Ameritrade.

Paperwork needed from charity to transfer assets from the TD Ameritrade IRA to the charity’s Non-TD Ameritrade external account:

  1.  Letter of instruction on charity’s letterhead detailing the Tax ID and the intention to transfer the IRA assets to the charity’s account -- signed by an authorized agent who is listed on the corporate resolution as an authorized party
  2.  IRS 501(c)(3) approval letter 
  3.  Copy of charity’s corporate resolution showing who is authorized to sign for the organization
  4. Completed TD Ameritrade Partial Transfer Form signed by an authorized agent
  5. Copy of the charity’s external account statement (displaying its account number and title) which is the account to receive the IRA assets ·
  6.  Documents should be sent to:

TD Ameritrade
P.O. Box 2760
Omaha, NE  68103-2760
Fax: 866-468-6268

Questions/Contact:
Aaron Bliss 
Manager - Ops & Clearing Compliance 
aaron.bliss@tdameritrade.com 
402-970-4192 (HOTC Floor 8)

B. Institutional IRA Instructions (see below):
External Receiving Account

Document Requirements:

  • Contra Firm's* Transfer Form      *Contra firm means the charity’s outside brokerage firm
  • Copy of the Receiving Account
  • Letter of Instruction (LOI) on Non-Profit’s Letterhead*
  • Formation Document (e.g., Corp Res) Listing Authorized Signer(s)  
  • IRS Document as Proof of Tax Exempt Non-Profit status**
  • Death Certificate***                                                                      

*LOI on non-profit’s letterhead detailing their Tax ID and their intention to transfer to their existing account at the other firm signed by an authorized agent.
**For external accounts, documented verification via secretary of state or IRS website may be accepted in lieu of the IRS document only. Formation document required to support transfer form signature.
***Only required if not yet received.

Your contra firm sends the paperwork to:
TD Ameritrade Institutional
PO Box 650567
Dallas, TX 75265-0567

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by TD Ameritrade require a new account to be opened first, prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

TIAA

Nonprofits have not had to open an inherited IRA account to receive their death benefits from IRAs. Nonprofits have described the process as smooth and received the check within a couple of weeks.

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by TIAA require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

T. Rowe Price

T. Rowe Price only requires a signed W-9 and a Letter of Instruction regarding no tax withholding (with a Medallion Signature Guarantee).

For non-tax qualified TOD (Transfer on Death Accounts)

Transfer on Death (TOD) accounts - they require completion of an ownership change form (Medallion Signature required), plus a new Mutual Fund New Business Account Form.

 

Truist

Truist Bank allows charities to receive IRA proceeds without opening an Inherited IRA account.

Note, however, Truist Investment Services, Inc., requires an Inherited IRA (they call it a BDA-IRA).
 

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Truist or Truist Investment Services, Inc., require a new account to be opened first – prior to being paid on a donor’s TOD account.​ If you have information on this issue, please let RIFT know in the Contact Us Section.

 

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, encourage the branch staff to obtain the correct corporate policy from Tammy Bawnik, Managing Director of UBS Legacy Advisory Services. Tammy Bawnik has stated she does not wish to receive phone calls from nonprofits but, after multiple requests, has not provided the name of the correct person who will take nonprofit phone calls.  RIFT pleads with UBS to work with the charitable sector on this issue.

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

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by UBS require a new account to be opened first – prior to being paid on a donor’s TOD account.​ If you have information on this issue, please let RIFT know in the Contact Us Section.

 

US Bank

US Bank does not require a charity to open an inherited IRA if the charity is 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.

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by US Bank require a new account to be opened first – prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.

 

Vanguard

While Vanguard typically allowed charities to receive the IRA death proceeds without setting up an Inherited IRA only if you requested an exception, since December 2020, charities no longer need to ask for an exception and you can receive a lump sum check by doing the following:

  1. Complete Vanguard’s form. You’ll need the last 4 digits of the deceased’s SSN and the last known mailing address to complete it.
  2. Provide a document showing who can execute financial instruments on behalf of the charity
  3. Provide a W-9
  4. Charities state that sending in your articles of incorporation is no longer required.
  5. However, we’ve also been told that Vanguard will not notify a charity if they are a beneficiary.

 

We’ve also been given this person’s name as a helpful individual if you run into issues with Vanguard:

Chris Milano
Case Manager Specialist
Vanguard
800-379-1727 Ext 15050
Business Days 8:30 a.m. - 5 p.m. Eastern time
beneficiaryteam@vanguard.com

If you are getting conflicting information from Vanguard, let Johni Hays know at johni@ceplan.com.

For non-tax qualified TOD (Transfer on Death Accounts)

Transfer on Death (TOD) accounts held by Vanguard require a new account to be opened first, prior to being paid on a donor’s TOD account.  It is unclear why IRAs do not require a new account but TOD accounts do.

Although the RIFT project originally began as an IRA issue, many nonprofits have let us know they are having trouble receiving death benefits when their donors have made the charity a beneficiary of an after-tax account - often referred to a TOD (Transfer On Death) account. These accounts are invested with after-tax dollar and are not pre-tax accounts like IRAs, 401(k)s, 403(b)s, etc. Now, the RIFT project has an after-tax account sample letter for charities to use and customize to meet their own situation.

TOD sample letter. Note there is a suggested attachment to the letter. Also, we have had success when nonprofits copy their state's attorney general on the letter. Get the name address of your state's attorney general.

 

Wells Fargo Bank or Wells Fargo Advisors

It makes a difference which entity has your donor’s account – Wells Fargo Bank versus Wells Fargo Advisors.

WELLS FARGO BANK: 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. As of October 2019, Wells Fargo needed an IRA Beneficiary Claim Form (check the box in Section 3 for a Lump Sum). 

WELLS FARGO ADVISORS: The RIFT project has not had success with charities getting IRAs paid without opening an Inherited IRA account.

One charity had Wells Fargo Advisors transfer the IRA assets in-kind to another of the charity’s brokerage account at a NON-WELLS FARGO firm without liquidating the investments in the IRA.

Therefore, to attempt to push back against that policy, send Hays IRA Letter to: 

Ellen R. Patterson, Senior VP, General Counsel 
Wells Fargo Headquarters
420 Montgomery Street
San Francisco, CA 94104
800-869-3557

Note there is a suggested attachment to the letter. Also, we have had success with other custodians when a nonprofit copies their state’s attorney general on the letter and the state of the deceased donor. Get the name and address of your state’s attorney general.

For non-tax qualified TOD (Transfer on Death Accounts)

RIFT has not been informed if TOD accounts held by Wells Fargo Bank or Wells Fargo Advisors require a new account to be opened first, prior to being paid on a donor’s TOD account. If you have information on this issue, please let RIFT know in the Contact Us Section.