In addition to the foregoing, CTC requires that fees be paid on or before the date that the trust documentation is executed by CTC. If you would like to wire these funds rather than remit payment by check, your assigned Trust Administrator assigned to your trust can provide the appropriate wiring instructions.
FIDUCIARY INCOME TAX RETURNS POLICY
CTC’s duties under most trust agreements (or Delaware law) typically include the preparation (or arrangement for the preparation) of the trust’s income tax returns. As such, unless prior arrangements are made with CTC for your CPA to prepare the relevant fiduciary filings, CTC will do so.
OFFICE OF FOREIGN ASSET CONTROL (“OFAC”) POLICY
CTC, as a directed trustee, exercises its investment authority at the direction of an individual with authority over trust investments, typically referred to as the investment advisor. Both the trust, and CTC, must comply with all OFAC sanctions including any prohibitions on new investment in and with certain industries, entities, or jurisdictions and all OFAC Specially Designated Nationals and Blocked Persons List (“SDN”) designations. As such, unless otherwise informed by the individual with investment authority over the trust, CTC will proceed with the understanding that: (i) the trust does not own any investments subject to OFAC investment prohibitions, (ii) the trust does not exist for the purpose of holding, selling, or purchasing assets on behalf of a party subject to any OFAC sanctions, list-based or otherwise and (iii) the trust is not participating in transactions with an individual designated as an SDN. CTC cannot participate in any trust which have assets subject to any OFAC prohibitions (i.e. Russian Harmful Foreign Activities new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071, etc.).
REAL PROPERTY POLICY
Due to jurisdictional issues, CTC: (i) cannot accept contributions of real property directly to a trust, and (ii) will not serve as Trustee of a trust that acquires direct ownership of real property. Real property must be owned by a closely-held entity (such as an LLC or Limited partnership), and the interests in that entity may be contributed or assigned to the Trust.
SPECIAL ASSETS POLICY
CTC must be informed of all new trust investments promptly in order to perform its fiduciary duties. Where an asset is in violation of CTC’s internal policies, CTC reserves the right to reject any transfer of assets. The exercise of this power to reject is not intended to be an exercise of investment discretion, but an administrative act meant to prevent the holding of assets which are either inconsistent CTC’s directed trustee role or for which CTC will not be able to sufficiently exercise its custodial responsibilities. In addition, CTC cannot participate in investments which violate state or federal law. The individual with investment authority over trust assets should inform CTC prior to any such investment by the trust.