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1. Contact us by phone or Secure Upload as soon as you become aware of the death of an account holder.

   To initiate a death claim, you must first:

   1. Provide us with a complete copy of the decedent’s death certificate (front and back) via Secure Upload. (We do not require an original death certificate).
   2. Reference the account number(s) in the comments of the Secure Upload.
   3. Read the information below and follow the additional instructions that apply to each account type.

2. Once we receive notice of the death of an account holder, the following actions will occur:

   1. We will completely restrict accounts that report under the decedent’s SSN, but we will not restrict joint accounts on the death of only one of the account holders. Once an account is restricted, asset based fee advisory billing will be turned off for firms for which we process billing. Before the death claim is processed, any fees assessed after the date of death will be refunded to the decedent account.

3. To distribute account assets, we require the following:

   1. If the inherited account is still invested and being moved internally to multiple accounts, we require instructions for the precise quantity of shares to be transferred to each account, ensuring that no shares remain in the decedent account. Review the Internal Account Transfer Form for a template for such instructions.
   2. If the assets are eligible to be distributed directly from the decedent account, the funds in the decedent’s account will be payable to, and mailed directly to, the designated beneficiary or estate executor. We will not process transfers to other financial institutions directly from a decedent account.

1. If date of death is in the current year and the current year Required Minimum Distribution (RMD) was not satisfied prior to death, the RMD should be processed when the funds are transferred to the beneficiary, and we will provide an IRS Form 1099-R .

After inherited IRA assets are moved to an inherited IRA, the beneficiary may maintain the account with us or move the funds by means of an account transfer -- please contact the receiving firm to initiate this process. IRA Accounts (including Traditional, Roth, SEP, SIMPLE, Rollover, etc.)

IRA — Spousal Beneficiary

As a spousal beneficiary, you may transfer the assets into an Inherited IRA or into an IRA of your own.

For an Inherited IRA, we require you to:

1. Open an Inherited IRA account.
2. Submit an Internal Account Transfer Form.

For your own IRA, we require you to:

1. Open a Traditional (or Roth, if applicable) IRA
2. Submit an Internal Account Transfer form

^* Current year RMDs, if not previously satisfied by the deceased account holder, must be taken by the beneficiary after the transfer of funds has taken place.

IRA — Non-spousal Beneficiary

As a non-spousal beneficiary of an IRA, we require the following:

1. Open an Inherited IRA account.
2. Complete and submit an Internal Account Transfer Form.

^* Current year RMDs, if not previously satisfied by the deceased account holder, must be taken by the beneficiary IRAs after the transfer of funds has taken place.

IRA — Trust Beneficiary

If a trust was named as the beneficiary, then open an Inherited IRA owned by the trust and request an internal transfer using the Internal Account Transfer Form, or request payment of the funds to the trust by doing the following:

1. Complete Trustee Change Form, if required to identify a trustee that was not previously identified to us.
2. Submit a signed Letter of Instruction (LOI) that includes where a check payable to the trust can be mailed.
3. Provide a W-9 with the TIN (Tax ID #) or EIN verification letter provided by IRS for the trust (should also be included on LOI).

IRA — No Beneficiary or Estate Beneficiary

If there were no named beneficiaries designated on the IRA, or the estate was named as the beneficiary, then then open an Inherited IRA owned by the estate and request an internal transfer using the Internal Account Transfer Form, or request payment of the funds to the estate by doing the following:

If an estate has been formed, the executor must:

1. Submit court approved copy of Letters of Testamentary/Administration.
2. Submit a signed Letter of Instruction (LOI) that includes where a check payable to the estate can be mailed.
3. Provide a W-9 with the TIN (Tax ID #) or EIN verification letter provided by IRS for the estate (should also be included on LOI).

If no estate has been formed:

1. Submit executed court documents verifying to whom the assets may be paid.
2. Follow the previously identified process for Spousal or Non-Spousal Beneficiaries.

IRA — Charitable or Business Beneficiary

Open an Inherited IRA owned by the charitable or business entity and request an internal transfer using the Internal Account Transfer Form, or request payment of the funds to the charitable or business entity by doing the following:

1. Charity/Business Entity - LOI from the charity on letterhead that includes the charity?s TIN/EIN and mailing address. An authorized representative of the charity/business entity with legal authorization (President, treasurer, officer, etc.) must sign the LOI, provide a photo ID to verify signature, and include documentation to validate they are authorized to act on behalf of the entity. Must include W-9. A Form 1099-R for the distribution will be mailed to the address provided in the LOI.

Individual Account with Designated TOD (Transfer on Death) Beneficiary

Named beneficiaries on the account must submit the following to process the claim:

• Signed Letter of Instruction (LOI) to pay the named percentage of the account to the beneficiary along with step-up and cost basis election (must be signed and include address).

OR

• Request a transfer to an existing taxable account held by us using an Internal Account Transfer form. Include step-up and cost basis election on Internal Account Transfer Form.

Individual Account with No Designated TOD (Transfer on Death) Beneficiaries —OR— Estate Beneficiary

If there are no TOD beneficiaries on this account, or the deceased’s estate was the named beneficiary; the funds will be paid to the estate, if one has been formed.

If an estate has been formed, the executor must:

1. Submit court approved copy of Letters of Testamentary/Administration.
2. Submit a signed Letter of Instruction (LOI) that includes where a check payable to the estate along with step-up and cost basis election should be mailed.

If no estate has been formed, the executor must:

1. Submit executed court documents verifying to whom the assets should be paid.
2. Submit a signed Letter of Instruction (LOI) that includes where the check should be mailed along with step-up and cost basis election.

OR

3. Request a transfer to an existing taxable account held by us using an Internal Account Transfer form. Include step-up and cost basis election on Internal Account Transfer Form.

Joint Account with Rights of Survivorship

As a surviving joint owner of this account type, there are two options:

1. Open an Individual (or Joint, if there were more than two owners) account and then request a transfer of assets using our Internal Account Transfer Form.

OR

2. Submit signed Letter of Instruction (LOI) to request the liquidation and closure of the joint account, with check made payable to remaining account owner(s) along with step-up and cost basis election.

Joint Account Tenants by Entirety

As a surviving spousal joint owner of this account type, you have two options:

1. Open an Individual account and then request a transfer of assets using our Internal Transfer Form.

OR

2. Request the liquidation and closure of the Joint account, with check made payable to remaining account owner(s) along with step-up and cost basis election.

Joint Account Tenants in Common

The decedent’s share of this account will be the property of their estate.

If an estate has been formed, the executor must:

1. Submit court approved copy of Letters of Testamentary/Administration.
2. Submit a signed Letter of Instruction (LOI) that includes where a check made payable to the estate should be mailed along with step-up and cost basis election.

If no estate has been formed, the executor must:

1. Submit executed court documents verifying to whom the assets may be paid.
2. Submit a signed Letter of Instruction (LOI) that includes where the check should be mailed along with step-up and cost basis election.

OR

3. Request a transfer to an existing taxable account held by us using an Internal Account Transfer form. Include step-up and cost basis election on Internal Account Transfer Form.

Joint Account Community Property

The deceased’s share of this account will be the property of their estate.

If an estate has been formed, the executor must:

1. Submit court approved copy of Letters of Testamentary/Administration.
2. Submit a signed Letter of Instruction (LOI) that includes where a check made payable to the estate should be mailed along with step-up and cost basis election.

If no estate has been formed, the executor must:

1. Submit executed court documents verifying to whom the assets may be paid.
2. Submit a signed Letter of Instruction (LOI) that includes where the check should be mailed along with step-up and cost basis election.

OR

3. Request a transfer to an existing taxable account held by us using an Internal Account Transfer form. Include step-up and cost basis election on Internal Account Transfer Form.

Custodian of UTMA Account Deceased

If the custodian of an UTMA account is deceased, we require the following from the new custodian:

• Death Certificate
• Court documents (requirements vary by state, please consult legal counsel for questions) naming a successor custodian.

Select one of the following two options:

1. Signed LOI to liquidate and close the account from the successor custodian

OR

2. Internal Account Transfer Request to a new account for the same minor, titled with the new custodian

Minor Named on UTMA Account Deceased

Funds for this type of account will belong to the estate of the deceased minor. We will need from the listed custodian:

If an estate has been formed:

1. Submit Letters of Testamentary/Administration (see court or legal documents).
2. Submit a signed LOI that includes where a check payable to the estate should be mailed.

If no estate has been formed:

1. Submit executed court documents verifying to whom the assets should be paid.
2. Submit a signed LOI that includes where the check should be mailed.

Select one of the following options:

1. If the trust is under an EIN, you may keep the account as-is after updating the Trust Parties on the Account Settings page (e.g., removing decedents from the Trustee and Authorized Signatory roles, updating beneficiaries and noting if a grantor is now deceased).

OR

2. If the Trust is under a natural person's Social Security Number we would close the account. A trustee that is on file with us can submit a signed Letter of Instruction (LOI) to liquidate the holdings and send the proceeds to the Trust (specifying the SSN of the Trust) - note that we will not send funds to individual beneficiaries, only to the trust. The advisor can also open a new Trust account with us using the new Trust EIN and submit an Internal Account Transfer form signed by a trustee that is on file with us.

We will need:

• Death Certificate
• Trustee Indemnification Form, if not already on file