Initial IRA Distributions upon Death

Contact Call Me Direct (CMD) Ext. 397100 prior to distributing funds to an IRA beneficiary.

To distribute IRA funds upon the death of the Individual Retirement Account (IRA) holder, make sure that you know the following four aspects:

  1. State where the account is held.
  2. Type of IRA -- Traditional or Roth.
  3. Type of beneficiary -- spouse or non-spouse Note: Options are chosen for distribution.


  1. For IRA accounts held in Florida, start here. Otherwise, Skip to step 2.

    CMD Ext. 397100 prior to distributing funds to an IRA beneficiary in Florida.

    The custodian determines if the deceased IRA owner was married on the date of death because the designation of the spouse as beneficiary does not survive the dissolution of marriage. If the IRA owner was divorced after the IRA was established, the former spouse does not receive the IRA account funds unless the IRA owner afterward signed an IRA Designation or Change of Beneficiary form to name the former spouse as the primary beneficiary.

    1. Verify the identity of the person making the request by using one of the following: 
    2. Determine the individual’s relationship to the IRA owner.
    3. In Xperience > Customer & Account Inquiry.
    4. Enter the account number, client name, Client Identification File (CIF), or TaxID.
    5. Click Related Functions > Document Image/Inquiry.
    6. Review the document to determine if the requestor is the named IRA beneficiary from the most recent IRA beneficiary form.
    7. Obtain a state-issued death certificate for the IRA owner. 
    8. Determine the marital status of the IRA owner as listed on the death certificate.
    9. If the death certificate indicates the IRA owner was married on the date of death, then do the following:
      1. If the primary beneficiary makes the request:
        1. If the primary beneficiary is not and has never been the spouse of the IRA owner, pay the funds to the primary beneficiary.
        2. If the primary beneficiary named on the IRA documents is the current spouse of the IRA owner, pay the funds to the current spouse. 
        3. Obtain the primary beneficiary’s signature on the Affidavit of Primary Beneficiary form.
    10. If the death certificate indicates the IRA owner was divorced on the date of death, then do the following:
      1. If the primary beneficiary makes the request:
        1. Determine if the primary beneficiary is the former spouse of the IRA owner.
        2. If the primary beneficiary is not the former spouse and has never been the spouse of the IRA owner, pay the funds to the primary beneficiary.
        3. DO NOT disburse the funds to the primary beneficiary if he/she is the former spouse. The former spouse is not entitled to the funds in the IRA account unless the divorced IRA owner signed a revised IRA Designation or Change of Beneficiary form after the divorce naming the former spouse as the primary beneficiary.
        4. Obtain a copy of the IRA Designation or Change of Beneficiary form to verify the beneficiary.
        5. Verify the date of execution on this document, if applicable. If the former spouse is listed as the primary beneficiary and the date of execution is after the dissolution of marriage, the funds can be paid to the former spouse.
        6. Note: If the IRA owner did not change the primary beneficiary and no contingent beneficiaries are named, do not pay the funds to the former spouse. The beneficiary of the funds is the estate of the deceased IRA owner.
        7. If the IRA owner listed a contingent beneficiary on the IRA document, pay the funds to the contingent beneficiary.
      2. If the contingent beneficiary makes the request, you can disburse funds to him/her under the following conditions (all of the following MUST be met):
        1. A contingent beneficiary is named on the IRA document
        2. The IRA owner was divorced on the date of death
        3. The primary beneficiary is the former spouse
        4. The IRA owner did not change the beneficiary after the divorce
        5.  The contingent beneficiary executes an Affidavit of Secondary Beneficiary form stating the IRA owner and the primary beneficiary were not married prior to receiving the funds
        6. Pay the funds to the contingent beneficiary after the affidavit has been executed
    11. If the death certificate does not state the marital status of the deceased IRA owner:
      1. If the primary beneficiary makes the request:
        1. If the primary beneficiary is not the spouse or former spouse, pay the funds to the primary beneficiary
        2. If the primary beneficiary requests the IRA funds and is the current spouse, he/she MUST execute an Affidavit of Primary Beneficiary form stating he/she was married to the IRA owner on the date of death
        3. Obtain a signed affidavit prior to disbursing the funds to the primary beneficiary
      2. If the contingent beneficiary makes the request:
        1. If the contingent beneficiary requests the IRA funds, he or she MUST execute an Affidavit of Secondary Beneficiary form stating the primary beneficiary is the former spouse and the IRA owner and primary beneficiary (former spouse) were not married on the date of death
        2. Obtain a signed affidavit prior to disbursing the funds to the contingent beneficiary


  2. Set up Beneficiary IRA Custodial Agreement

    Contact CMD Ext. 397100 who assist in determining the appropriate IRA beneficiary. After determining the appropriate IRA beneficiary with the help of CMD, set up the Beneficiary IRA Custodial agreement by doing the following:

    1. Verify the identity of the person making the request by using one of the following: 
    2. Determine the individual’s relationship to the IRA owner.
    3. In Xperience > Customer & Account Inquiry.
    4. Enter the account number, client name, CIF or TaxID.
    5. Click Related Functions > Document Image/Inquiry.
    6. When the IRA owner has died, complete the appropriate beneficiary custodial agreement, either a Traditional Beneficiary IRA Custodial agreement or a Roth Beneficiary IRA Custodial agreement for each beneficiary.
    7. Complete all information in sections 1–4 of the custodial agreement. Section 3 allows the beneficiary to designate successor beneficiaries.
    8. Review the form with the beneficiary.
    9. Complete an IRA Election of Payment by Beneficiary form for each beneficiary (only complete for contingent beneficiaries if primary beneficiaries are deceased).
    10. Each beneficiary MUST elect payment based on whether he/she is the IRA owner’s spouse or non-spouse beneficiary and after seeking professional financial guidance.
    11. The following procedures apply for death distributions based on the beneficiary’s election of payment in section 3 of the IRA Election of Payment by Beneficiary form.


  3. Based on the four aspects above, choose a combination from this table and then expand the matching option below it:
    Beneficiary
    by IRA type    		 Distribution Options
    Before or After Required Begin Date Other Options
    Spouse (Traditional and Roth) --- ---
    --- Before Treat as own
    --- Before Five-year rule
    --- Before Single-life expectancy 
    Spouse (Traditional) --- ---
    --- After Single-life expectancy
    --- After  Treat as own

    		--- ---
    Non-spouse (Traditional and Roth) --- ---
    --- Before Five-year rule

    • Spouse (Trad/Roth) - Before, Treat As Own

      For a spouse beneficiary when the IRA owner’s death occurred before the required beginning date and the beneficiary selects Treat as Own:
      1. Recall the IRA owner’s certificate/account in the system to produce the IRA Distribution Form. 
      2. Mark the distribution reason as Death.
      3. Complete an IRA Election of Payment by Beneficiary form.
      4. Type a new CD for the spouse’s IRA in the amount of the distribution from the IRA owner.
      5. Complete an IRA Custodial agreement for the spouse unless one already exists on the system.
      6. Upload the new CD and place the IRA forms and other documents not submitted via eSign with the daily work for imaging.

    • Spouse (Trad/Roth) - Before, Five-year Rule

      For a spouse beneficiary when the IRA owner’s death occurred before the required beginning date and the beneficiary selects Five Year Rule:

      1. Recall the IRA owner’s certificate/account into the system to produce the IRA Distribution Form. 
      2. For the distribution reason, indicate Death.
      3. Close the deceased owner’s IRA.
      4. Issue a new CD titled in the following format: Jane Doe, as the beneficiary for John Doe’s IRA in the amount of the net settlement from the CD Closing Entry Calculation screen.
      5. Complete a Beneficiary IRA Custodial Agreement or IRA Contribution form (if the spouse has IRA plan with CCB) and IRA Election of Payment by Beneficiary form.
      6. If the spouse beneficiary requests a full or partial distribution, complete a Beneficiary IRA Distribution form marking the distribution reason as Death.
      7. Upload the new CD and place the IRA forms and other documents not submitted via eSign with the daily work for imaging.
      8. Prepare a money order for the amount withdrawn payable in the following format: Jane Doe, as a beneficiary of John Doe’s IRA. 
      9. Offset the credit copy of the money order with a General Ledger (GL) debit to CD Settlement. 
      10. Record the IRA account number, associate name, and location on the GL ticket.
      11. For each subsequent distribution over the five-year period, perform steps h through j.


    • Spouse (Trad/Roth) - Before, Single-life Expectancy

      For a spouse beneficiary, when the IRA owner's death occurred before the required beginning date and the beneficiary selects Single Life Expectancy:

      1. Recall the IRA owner’s certificate/account into the system to produce the IRA Distribution Form. 
      2. For the distribution reason, indicate Death.
      3. Close the deceased owner’s IRA.
      4. Issue a new CD titled in the following format: Jane Doe, as the beneficiary for John Doe’s IRA in the amount of the net settlement from the CD Closing Entry Calculation screen.
      5. Complete a Beneficiary IRA Custodial Agreement or IRA Contribution form (if the spouse has IRA plan with CCB) and IRA Election of Payment by Beneficiary form.
      6. If the spouse beneficiary requests a full or partial distribution, complete a Beneficiary IRA Distribution form marking the distribution reason as Death.
      7. Upload the new CD and place the IRA forms and other documents not submitted via eSign with the daily work for imaging.
      8. Prepare a money order for the amount withdrawn payable in the following format: Jane Doe, as a beneficiary of John Doe’s IRA. 
      9. Offset the credit copy of the money order with a GL debit to CD Settlement. 
      10. Record the IRA account number, associate name, and location on the GL ticket.
      11. For each subsequent distribution over the five-year period, perform steps h through j. 


    • Spouse (Trad) - After, Treat as Own

      For a spouse beneficiary, when the IRA owner's death occurred after the required beginning date and the beneficiary selects Treat as Own:

      Note: The spouse beneficiary MUST take the minimum distribution for the tax year.

      1. Recall the IRA owner’s certificate/account in the system to produce the IRA Distribution Form. 
      2. For distribution reasons, choose Death.
      3. Close the deceased owner’s IRA account.
      4. Type a new CD titled in the following format: Jane Doe, as the beneficiary for John Doe’s IRA for the amount of the distribution from the IRA owner.
      5. Complete the Beneficiary IRA Custodial agreement and the IRA Election of Payment by Beneficiary form.
      6. Complete a Beneficiary IRA Distribution form for the minimum distribution for the year (if it has not already been taken). 
      7. Mark distribution reason as Death.


    • Spouse (Trad) - After, Single-life Expectancy

      For a spouse beneficiary, when the IRA owner's death occurred after the required beginning date and the beneficiary selects Single Life Expectancy.

      1. Recall the IRA owner’s certificate/account in the system to produce the IRA Distribution Form. 
      2. For the distribution reason, choose Death. 
      3. Close the deceased owner’s IRA account.
      4. Type a new CD titled in the following format Jane Doe, as the beneficiary for John Doe’s IRA for the amount of the required minimum distribution from the IRA owner.
      5. Complete the Beneficiary IRA Custodial agreement and the IRA Election of Payment by Beneficiary form.
      6. Complete a Beneficiary IRA Distribution form for the required minimum distribution for the year (if it has not already been taken).
      7. Mark distribution reason Death.
      8. Upload the new CD and place the IRA forms and other documents not submitted via eSign with the daily work for imaging.
      9. Issue a money order for the amount of the distribution payable in the following format: Jane Doe, as a beneficiary of John Doe’s IRA.
      10. Offset the credit copy of the money order with a GL debit to CD Settlement. 
      11. Record the IRA account number, associate name, and location on the GL ticket.


    • Non-spouse (Trad/Roth) - Before, Five-year Rule

      For a non-spouse beneficiary when the IRA owner's death occurred before the required beginning date and the beneficiary selects Beneficiary's Single Life Expectancy Reduction Method or the Five year Rule:

      1. Recall the IRA owner’s certificate/account in the system to produce the IRA Distribution Form. 
      2. Mark Death as the distribution reason.
      3. Close the deceased owner’s IRA account.
      4. Type a new CD titled in the following format: Jane Smith, as the beneficiary for John Doe’s IRA in the amount of the distribution from the IRA owner.
      5. Complete a Beneficiary IRA Custodial agreement and an Election of Payment by Beneficiary form.
      6. If the beneficiary requests a distribution, complete the Beneficiary IRA Distribution Form.
      7. Mark Death as the distribution reason.
      8. Upload the new CD and place the IRA forms and other documents not submitted via eSign with the daily work for imaging.


  4. Process the distribution by doing the following:
    1. Prepare a money order for the amount withdrawn payable in the format of Jane Smith as a beneficiary of John Doe’s IRA.
    2. Complete a CD Settlement GL debit ticket 310-245105-6302-000 for the amount of the closing entry with the following information:
      • Date
      • Client name
      • Brief description
      • IRA CD account number in boxes above the MICR line
      • Amount of IRA/CD
      • Associate's first initial, last name, and extension
    3. Have the client sign the CD Settlement GL Debit.
    4. If the client is not present, have two associates sign the CD Settlement GL debit.
    5. Take the CD Settlement GL debit ticket and the offsetting credit to the teller line for processing.
    6. If unable to process at a teller line, a place with the work for processing in Office Capture.

As each subsequent distribution occurs over the 5 year period, prepare a beneficiary IRA distribution form for each distribution marking the distribution reason Death. 

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