If I am a beneficiary on an account at a bank, but I do not have an account at the bank, do you consider me a bank customer? Let's say I come into the bank to open a new and first time checking account with you, do you know that I'm a beneficary on someone else's account?

In our bank you would be a new customer even if you were the beneficiary on another account. Many banks do not collect the information that is required for new customers at the time that a person is named as a beneficiary. We are required to verify identity, physical address, etc. on all "New" customers. If and when we pay the money to a beneficiary, we will collect it at that time unless we already have it in the system from another account. The reason for not collecting the info on a beneficiary is that they are often out of market and many times the beneficiary is changed or the account is closed by the owner before funds are ever distributed to a beneficiary.

Now, if you came in and opened an account with us while you were the beneficiary on another existing account, we would collect the required info at the time of account opening.

If your only relationship with our bank was beneficiary on an account, we would not consider you a customer for regulatory purposes. We sure would like to make you a customer though.

For example, perhaps you were to walk in a bank and want to cash a check that is not drawn on their bank (meaning if you go to BankofA, and the check was drawn on Commerce.) Most banks require some type of deposit account to do that (savings, checking, just in case if it "bounced" the bank would have somewhere to collect the funds from. You would not be able to use the account that you are the beneficiary on to cash the check because those funds are not entitled to you as of yet.