Frequently Asked Questions
General
You are welcome to call us for this information or view it online. If you aren't already signed up for online access through CNB, please complete the Online/eStatement Authorization for Account Owners form.
CNB will need to receive an Affidavit for Power of Attorney as well as a copy of the power of attorney document. Other documents may be required depending on the language within the power of attorney document (i.e. doctor's statement indicating incapacity, etc.).
No, CNB will not provide a medallion guarantee for customer signatures. If a medallion guarantee of your signature is required, it must be obtained before forms are sent to our office. We will medallion guarantee our own custodial signature on the form when required for processing.
IRA accounts may receive annual, quarterly, or monthly statements depending on the frequency selected by the account owner. Non-Qualified accounts receive monthly statements. A fee is assessed for each paper statement issued. Online access and eStatements are available free of charge by completing the Online/eStatement Authorization for Account Owners form.
Investments
To continue to hold the exchange-traded stock in your account at CNB, no action is required. Because each listing is different, when an investment lists on the public market an email will be sent to your designated rep with further details regarding the ability to sell, transfer, or liquidate through a possible tender offer. We will be happy to forward this information to you as well if you contact us.
Please obtain the appropriate form from the product sponsor. Complete and sign the form, and return to CNB for our signature. We will then forward the completed form to the product sponsor and follow-up to ensure your request is completed. In cases where the product sponsor does not require their specific form be used, submit a simple letter of instruction to CNB and we'll provide the necessary paperwork to the product sponsor.
We custody a wide variety of investments including non-traded REITs, BDC's, limited partnerships, limited liability companies, private placements, debentures, certificate of deposits, interval funds, real estate, precious metals and more. If there is an investment you would like to include in your account at CNB please call us to verify prior to submitting paperwork. CNB reserves the right to accept or deny any investment for custody. Due to the wide variety of investments accepted for custody at CNB, we do not publish a comprehensive list.
Account Maintenance
Complete the Representative Designation form to provide us with your new representative's information. The form will need to be signed by you and your new representative.
Complete the Representative Change form to provide us with your new broker/dealer, contact information, or list of clients you are no longer working with. We do not require client signatures on this form. Please note that this will not automatically change the representative at the fund company level, additional paperwork may be required by the fund companies.
You may either call us or complete our Account Update form to update your mailing, physical, or email address. The account update form must be completed for a name change. We will also require supporting documentation such as a marriage certificate, divorce decree, court ruling, etc for a name change. CNB cannot accept your designated representative's signature for these requests. A power of attorney, guardian, or conservator already assigned to the account would be allowed to sign the form.
For security purposes and protection of our clients, CNB requires a notary on the Designation or Change of Beneficiary form. There are no exceptions.
The only time the spouse is required to sign the Spousal Consent section of a Designation or Change of Beneficiary form is when the spouse is NOT listed as 100% primary beneficiary.
IRA statements are issued on a monthly, quarterly or annual basis, depending on how you have set up your account. This frequency can be changed at any time by completing the Account Update form. Non-Qualified accounts must receive a monthly statement. There is a charge for each paper statement issued. eStatements are available at no charge regardless of the statement frequency. You may sign up for eStatements using our Online/eStatement Authorization for Account Owners form.
Duplicate paper statements can be produced for an additional charge. Please call our office in order to process this request. If you have online access, you may view and print statements at any time.
New Accounts
Refer to our document Four Easy Steps for Setting up an IRA when opening a new IRA account. To open a new non-qualified account, see our Easy Steps to a Non-Qualified Account document. Please call our New Accounts Department at 800-680-0340 ext 6810 with any questions.
The one time set up fee and annual base fee are due when a new account is opened. The account owner may submit a check with the paperwork or contact our office to pay by credit card once the paperwork is received at CNB. These fees can also be deducted from any cash transferring into the account. At the end of each calendar year, CNB will assess any supplemental fees for activity that occurred during the year such as purchases, statements, holding fees, etc. Please see the Fee Schedule for a detailed listing of our fees.
It may be in your best interest to designate beneficiaries. Please consult with your tax, financial, and/or legal advisor. If no beneficiaries are listed on the IRA application, the default will be listed as Estate. If the account owner is married, then CNB will require the spousal consent section be completed.
CNB requires spousal consent on all IRA's if the account owner is married and not listing the spouse as 100% primary beneficiary.
Transfer on death is only applicable to Individual, Joint, or Tenants in Common types of accounts. If it is not completed for these account types the default transfer on death will be the estate.
Yes, if you need a pre-assigned account number to complete a rollover from a qualified retirement plan, please give us a call!
Transfer-In/Rollover-in/Contributions
You will need to complete CNB's Transfer Request form for non-qualified accounts and attach a statement showing the asset(s) that will be moving to CNB. If you do not already have an account opened at CNB, we will also require the Non-Qualified Account application. CNB will then request the assets from the other custodian.
CNB will accept a copy, fax, or scanned image of our Transfer Request form as long as the current custodian (where the funds will be coming from) will accept a copy of the client's signature.
A Traditional or Roth IRA contribution for any tax year must be postmarked and mailed to CNB by the due date (not including extensions) of an IRA owner's federal income tax return for that year. This is typically April 15th of the following year. If April 15th falls on a weekend or holiday, the deadline moves to the next business day. For a SEP IRA, employers must deposit their annual SEP contributions by the due date of their federal tax return plus extensions.
All checks must be made payable to Community National Bank or CNB. Send the check and Contribution form to CNB.
Yes, complete the Authorization Agreement for Automated Contributions section on the Contribution form to establish a monthly or quarterly ACH contribution from a checking or savings account to a Traditional, SEP or Roth IRA. Contributions will be coded for the tax year in which they are received unless you submit written instructions to CNB.
Online Access/Website
If you have not signed up for online access or eStatements, you will need to complete the CNB Online/eStatement Authorization for Account Owners form. You can view your account online by visiting www.cnbcustody.com. You will then click on the Account Access Button to log-in. If you have signed up for eStatements, you will go to the statements tab when logged in to view your statements.
Yes, representatives designated by the account owner may view their clients' accounts by completing our Online/eStatement Authorization for Representative form.
You are not able to view the accounts of multiple individuals using the same Internet ID. Each account owner is required to have his or her own Internet ID. If you have multiple accounts under the same social security number (such as a Traditional IRA and a ROTH IRA) you may access each of them with the same Internet ID. For non-qualified accounts with multiple owners, only the primary owner will be issued an Internet ID.
Distribution
Complete the Distribution Request form to take a distribution of either cash or shares of an investment from your IRA. For distributions of investments, investment company re-registration forms must be completed and returned to CNB along with the Distribution Request form. If the fund company charges a re-registration fee we will deduct it from the cash available in the savings balance portion of the IRA. If there is not cash available in the savings balance of the IRA you may either submit a check or pay via credit card by going online or calling us.
IRS regulations require you to take a Required Minimum Distribution (RMD) from your Traditional IRA each year beginning the year you turn 72. The RMD is based on your fair market value for the previous year-end and your life expectancy divisor provided by the IRS. Your annual RMD amount is found on your December 31st statement. The IRS may impose a penalty on the amount of the RMD that is not withdrawn by the deadline.
To take the RMD from your IRA, complete the Distribution Request form and submit to CNB. If sufficient cash is available in your IRA you will not need to do anything else. If there is not enough cash available in your IRA to cover your RMD, please contact your designated representative for advice.
If the investments in your account are not able to be liquidated or provide sufficient cash dividends to meet the RMD, you may need to take a distribution in-kind of an investment in your IRA. Please contact your designated representative to see if this a good option for you. If you decide to take a distribution in-kind, all paperwork will need to be received by CNB no later than the deadline listed on our website to ensure proper processing time for the December 31st deadline.
The RMD amount may also be removed from an IRA held elsewhere. A Waiver to Distribute Required Minimum Distribution form can be submitted to CNB so we know you have taken care of the RMD through another IRA.
Complete the Withdrawal Request form to remove either cash or shares of an investment from your account. For withdrawals of investments, investment company re-registration forms must be completed and returned to CNB along with the Withdrawal Request form. If the investment sponsor charges a re-registration fee, we will deduct it from the cash available in the savings balance portion of the account. If there is not cash available in the savings balance, you may either submit a check or pay via credit card by going online or calling us.
Closing/Transfer Out
In order to transfer your IRA from CNB to an IRA with another custodian, you must complete the receiving custodian's IRA transfer request form. We require the original form be mailed to us and include the receiving firm's letter of acceptance.
If you wish to take a distribution of the investments in your IRA and close your account, you will need to complete our Distribution Request form. You must also complete the investment company's change of ownership or re-registration form. Please refer to the deadline listed on our website for end of year distributions of investments to ensure completion by 12/31.
When an account at CNB closes, we charge a closing fee of $175 plus any current year transaction fees. Current year transactions fees could include paper statement charges, re-registration of investment fees (due to transfer, distribution, conversion, recharacterization, divorce, or death), sale of investment fees, etc. See our Fee Schedule for additional information.
Deceased Accounts
Please call us to report the death and discuss options for claiming the account.
You will need to complete our Beneficiary Claim form and provide CNB a photocopy of the death certificate. If you are a spouse beneficiary claiming the IRA as your own, we can journal the assets from the deceased account to your existing CNB IRA. If you are a spouse beneficiary, non-spouse beneficiary, or a non-individual beneficiary who does not have an existing IRA at CNB you will also need to complete our IRA Application. For estates, trusts, and charities, CNB also requires supporting documentation, which may include letters of testamentary, a complete copy of the trust, or a corporate resolution to verify who can act on behalf of the named beneficiary.
Taxes
The Tax Form 5498 reports IRA contribution information to the Internal Revenue Service. You will receive this form if you have made a contribution to your account, including rollover contributions, Roth conversions and re-characterized contributions. Since this form reports the prior year's contribution information, and account owners are able to make prior year contributions until the April 15th tax filing deadline, the form is required to be issued to the IRA owner by May 31st. The Form 5498 is provided to you as an informational copy that is not required to be filed with your tax return. CNB uses the year-end statement to report fair market value to the account owner.
The Form 1099-R reports IRA distribution information to the Internal Revenue Service. You will receive this form if you have taken distributions of cash or investments from your IRA. 1099s will be mailed by January 31st of each year.
The Schedule K-1 is a tax document used to report your share of the partnership's income, deductions, and credits. IRAs are normally exempt from current taxation on investments within the IRA. The Internal Revenue Code states, however, that an IRA is subject to the tax imposed on the Unrelated Business Taxable Income (UBTI) of certain organizations (generally limited partnerships). If the UBTI from all investments within your IRA is greater than $1,000, then your IRA may have a tax liability. UBTI, if any, is reported by the investment company to the investor on an annual K-1. See IRS.gov for additional explanations and consult your tax advisor for further information and assistance.
Purchase & Sales
Complete our Investment Authorization form and submit to CNB along with the purchase agreement from the investment company. Be certain that funds are available in the account or will be requested via a transfer, sale, contribution, etc. The purchase of any exchange-traded investments will need to be done through a brokerage account that your designated representative has established through his or her broker/dealer registered in the name of the CNB account.
The Investment Authorization form can be used to request the sale of mutual funds, annuities, or certain stocks that allow shares to be sold through a DRIP (Dividend Reinvestment Program). The form may be faxed to CNB to process the redemption request. The sale of most other investments will require a redemption form directly from the investment company. Once the investor has completed the investment company's redemption form, it will need to be submitted to CNB for signature, and we will forward it on to the investment company. The sale of any exchange-traded stocks will need to be completed through a brokerage account that your designated representative has established through his or her broker/dealer registered in the name of the CNB account.
A DVP account (Delivery vs. Payment), is a special type of brokerage account used to place trades on exchange-traded securities within the account at CNB. A DVP account must be set up by a financial representative through his or her broker/dealer using the following instructions: Instructions for Establishing a Brokerage Account.
A DVP or retail brokerage account will need to be set up by your designated representative using the Instructions for Establishing a Brokerage Account. This account can then be used to place a trade on an exchange-traded investment. If you are unsure whether to establish a DVP or retail brokerage account, please refer to the following information: Retail vs. DVP Accounts and verify with your broker/dealer which type of account they will allow.
Fees
You can mail a check, or call us to pay with a credit card, or pay online under the fees tab of the website.
The fee cannot be deducted directly from an investment in the account. If you would like to sell a portion of your investment or change the dividend option to cash to cover the fee, please discuss your options with your designated representative.
Since Congress is providing certain tax incentives for saving money through an IRA, an IRA must meet Internal Revenue Code requirements, which include the use of a bank or other entity approved by the IRS to act as either trustee or custodian. As your IRA custodian, CNB charges a fee to perform recordkeeping that tracks the activity within the account, produces statements for the account owner showing the activity and status of the account, and provides tax reporting of contributions, distributions, and fair market value to the account owner and the IRS.
Investing in Real Estate Through an IRA
No, CNB is a custodian and does not provide any financial advice. Please consult your financial advisor, tax preparer, or an attorney for advice on investing in real estate products.
Since Congress is providing certain tax incentives for saving money through an IRA, an IRA must meet Internal Revenue Code requirements, which include the use of a bank or other entity approved by the IRS to act as either trustee or custodian. As your IRA custodian, CNB is responsible for the recordkeeping that tracks the activity within the account, produces statements for the account owner showing the activity and status of the account, and provides tax reporting of contributions, distributions, and reports fair market value to the account owner and the IRS.
Making the Purchase
There are several ways to fund a real estate purchase in an IRA. You do not need to have the full purchase amount in your IRA to buy property. Options for funding include:
- Direct Purchase - Your IRA purchases the asset using only the cash from within the IRA.
- Partnering - You can partner with other investor's IRAs or personal funds to make the purchase. The investment income and expenses are divided among investors based on ownership percentage.
- Non-Recourse Loan - Your IRA can obtain a non-recourse loan to fund the purchase. The leveraged property is held in your IRA and all loan payments must be paid through your IRA.
This depends on the complexity of the transaction. It is a good idea to have your CNB account established and funded before you start searching for a property.
You may purchase a variety of investment properties and real estate, such as commercial buildings, vacant land, condos, farmland, and apartment buildings. We do not custody foreign properties or properties being purchased at auction. It is highly recommended that you use a title company when purchasing real estate to ensure that the deed is recorded in the name of your IRA.
At the time of initial purchase, your IRA can partner with anyone, including a disqualified person. But after the transaction is closed, your IRA cannot buy, sell, or transfer to any disqualified person.
No, the IRS does not allow using an IRA asset to secure a personal loan. Everything the IRA engages in must be for the exclusive benefit of the IRA. A prohibited transaction occurs when an IRA owner uses their IRA for their personal benefit rather than to benefit the IRA.
Yes, your IRA could obtain a non-recourse loan. The IRA is the borrower on the loan. The loan documents are signed by Community National Bank on behalf of the IRA at the direction of the IRA account owner.
A non-recourse loan is secured only with collateral, which is usually the property. If the borrower defaults, the lender can seize the collateral, but cannot go after the borrower for any further compensation, even if the collateral does not cover the value of the defaulted amount. The borrower does not have personal liability for the loan.
CNB requires a completed Real Estate Purchase Form. Your account must have sufficient funds before engaging in a transaction. Please contact us for details and specific requirements for your property type.
A real estate professional can assist you with performing the necessary due diligence on the property to fit your individual needs. Consulting with a tax professional and attorney to be certain you understand the IRS regulations for holding real estate within an IRA is highly recommended. See IRS Code 4975 for additional information
When considering a property, you will need to:
- Verify that the title can be held in the name of an IRA.
- Verify that the title company is familiar with self-directed IRA transactions.
- Set a realistic timetable for the transaction.
- Decide if you will be doing a direct real estate purchase or leveraging a non-recourse loan.
- Find someone to handle property management.
No, this is a prohibited transaction. Your IRA cannot buy property that you currently own or contribute property to an IRA. See IRS Code 4975 for detailed information on prohibited transactions, disqualified persons, and self-dealing.
The contract must be in the name of the IRA. The IRA account owner (or any disqualified person) cannot assign their interest to the IRA due to the potential for a prohibited transaction. The proper way to handle this is to start a new contract showing Community National Bank, Cust FBO: IRA Owner Name, IRA #xxxxxx as the purchaser.
The insurance policy must be in the name of the IRA. Community National Bank must sign the insurance agreement on behalf of the IRA.
Prohibited Transactions
No, this is a prohibited transaction. IRS Code 4975 states that the IRA holder is a disqualified person and the direct or indirect furnishing of goods, services, or facilities between an IRA and a disqualified person is prohibited.
No, because they are disqualified persons. Property owned by your IRA cannot be used in any way by you, your spouse, your lineal ascendants or decedents, or their spouses.
No, you cannot rehab the property either at no charge or the going rate because you are a disqualified person to your IRA. Companies owned by you are also not allowed to do any work on the property. The direct or indirect furnishing of goods, services, or facilities between an IRA and a disqualified person is not allowed.
No, you may not use the property in any way. The direct or indirect furnishing of goods, services, or facilities between an IRA and a disqualified person is prohibited. See IRS Code 4975 for information on prohibited transactions and disqualified persons.
No, not even free of charge, because you are considered a disqualified person. If you perform any work to improve or repair the property it is considered “sweat equity” and is prohibited. The direct or indirect furnishing of goods, services, or facilities between an IRA and a disqualified person is not allowed, see IRS Code 4975.
The IRA owner, their spouse, lineal ascendants or descendants (parents, grandparents, children, grandchildren, etc.) of the IRA owner and spouses of lineal ascendants or descendants, or any entity in which a disqualified person owns 50% or more are disqualified parties. See IRS Code 4975.
Possible prohibited transactions include:
- Buying, selling, or leasing property to a disqualified person
- A disqualified person using the property for personal use
- A disqualified person doing any repairs or maintenance to the property
- Paying expenses or receiving income outside of the IRA
Please see IRS Code 4795 for more details and other potential prohibited transactions.
If a prohibited transaction occurs within your IRA, the IRS may negate the entire IRA. In the event of a prohibited transaction, everything held within the IRA would be distributed. You would receive a 1099-R to report the distribution as taxable income and would be responsible for any taxes and penalties on those funds.
Income & Distributions
If the property is being managed by a property manager, the property manager collects the rent and sends it to us for deposit. If a property management company is not managing the property, the rental income should be sent directly to the IRA account. Rental checks must be made out to: Community National Bank CUST FBO: Account Owner Name, IRA #XXXXXX.
Yes, you can receive the rental payments for record keeping. The checks must be payable to the IRA and sent to CNB for deposit to your IRA. You cannot deposit the check in any other account.
All expenses for a property held in your IRA must be paid by the IRA. Using personal funds to pay for expenses is prohibited by the IRS, see IRS Code 4975. When you have an invoice to be paid, complete the Real Estate Expense Payment form and submit it along with the invoice. CNB will then pay the invoiced amount with your IRA funds.
All real estate expenses, such as mortgage payments, property taxes, insurance, HOA dues, repairs, and maintenance, must be paid from the IRA. Any expense paid with personal funds could be considered a prohibited transaction.
UBIT is incurred on debt-financed income, which is usually in the form of rent, interest, or royalties arising from leveraged property. If UBIT is due the IRA owner must file tax form 990-T for the IRA. Any taxes must be paid out of the IRA. See Publication 598 and visit with your tax preparer for more information.
Rental income must be deposited in the IRA first. After the deposit, you can request a distribution from the IRA. Your distribution may be subject to taxes or penalties, depending on your age and the type of IRA you own.
Property Manager
We strongly recommend using a property manager for income producing properties. A property manager is helpful for the purpose of consolidating the various expenses. If you are partnering with others, your tenants do not have to write multiple rental checks to the various investors. They can just write one to the property manager, who then distributes the percentages accordingly and sends the IRA's percentage to CNB. A property manager will receive & forward invoices for real estate taxes, insurance premiums, property maintenance expenses or management fees. They are responsible for communicating with governmental entities, etc. concerning easements. The property manager also notifies the custodian and account owner in event of default by a renter and takes action to correct.
No, you cannot be the property manager but you can hire any third party who is not a disqualified person to be the property manager. A Property Management Agreement is signed by the Account Owner and Property Manager for the benefit of the IRA.