Not to Be Indelicate, but …

This has complicated efforts of planned-giving fundraisers who foster trust relationships. The FTC states that when a financial institution serves as a trustee of a trust, neither the grantor nor the beneficiary is a consumer or customer under the rule. The trust itself is the institution’s customer, so the rule doesn’t apply because the trust is not an “individual.” Thus, nonprofits that meet the definition of a financial institution need not send disclosure notices to donors and beneficiaries of charitable trusts.