CITADEL TRUST ILIT Management Specialists
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We are uniquely dedicated to the complexities of Irrevocable Life Insurance Trusts.

Frequently Asked Questions

 

General Overview
Citadel Trust Company, a division of National Independent Trust Company (NITC), acquires existing ILITs from banks of all sizes. Citadel Trust offers expertise in the review, transfer and ongoing administration of ILITs. Given the national charter under which Citadel Trust Company operates, we are able to accept ILITs in all 50 states. We perform thorough due diligence on each trust vehicle, maintain top level administration of the trust and focus our expert analysis on the life insurance policy.
 
Citadel Trust Company maintains the excellent customer service you have always given to each grantor and beneficiary. With expertise in life insurance policy analysis, Citadel Trust, as the successor trustee, is responsible for all actions after the transfer to Citadel. Your bank would release itself from any future liability on any transferred ILITs. Any liability prior to the transfer of the ILITs would be retained by your bank.
 
Citadel Trust has the capacity to handle all of the qualifying ILITs which your bank wishes to transfer, and more. We are in the business of managing ILITs, their grantors and beneficiaries, their administrative tasks and the policies contained within. We have over 70 years of life insurance expertise and more than 17 years of Trust Company experience. Citadel's ability to accept the successor trusteeship of qualifying ILITs sets it squarely apart from any other alternative.
 
Citadel Trust Company will:
  • Perform a comprehensive review of the trust documents to ascertain transferability
  • Coordinate and implement the campaign to transfer the ILITs to Citadel
  • Provide a specialized national management structure in order to effectively incorporate all of your bank's ILITs
  • Transition your bank's ILITs onto the Citadel/NITC administrative system
  • Perform life insurance policy analysis on each policy contained within the ILITs
  • Manage the future premium collection & payment, performance reviews, annual contributions and "Crummey" notices
  • Prepare all necessary trust income tax returns
History & Background
Citadel Trust Company joined with NITC to acquire existing ILITs. National Independent Trust Company was formed from the conversion of the state charter of The Trust Company of Louisiana. NITC is regulated by the Office of Comptroller of the Currency (OCC) and enjoys nationwide branching authority.
 
Trust entities in other states, such as Citadel Trust, have affiliated with NITC creating current offices in Minnesota, West Virginia, North Carolina, Wisconsin, Ohio and Missouri. Citadel Trust Company, as our division based in Missouri, has full authority to conduct trust activities nationwide, through NITC.
 
Citadel Trust Company is the branded name for the ILIT management expertise shared between Citadel Trust and NITC. Together we offer the full range of Irrevocable Life Insurance Trust services.
 
Business Strategy and Models
 
Q:   What is the business strategy of Citadel Trust Company, a division of NITC?
 
A:   Citadel Trust Company acquires existing Irrevocable Life Insurance Trusts from banks of all sizes. Citadel Trust Company actively seeks to increase its number of ILITs under management. With expertise in life insurance policy analysis, Citadel Trust, as the successor trustee, is responsible for all actions post transfer (that is, the liability, per its agreement with its grantors, upon transfer to Citadel). Banks that choose to exit the ILIT business retain only the liability for actions prior to the transfer of ILITs. Citadel has the ability to acquire and manage ILITs in all 50 states. Citadel handles the fiduciary liability and administrative management of the ILITs through its parent company, NITC.
 
 
Q:   What does that mean or how does that work?
 
A1:   As it relates to Citadel Trust Company: The principals of Citadel Trust Company come from three generations of life insurance expertise. The staff consists of experts in life insurance analysis, ILIT administration, and the legal issues that surround the ILIT vehicle. As such, Citadel Trust is comfortable with the liability inherent to Irrevocable Life Insurance Trusts. Citadel engages with small, medium and large banks, some of which have only a small number of ILITs, others that have thousands of ILITs.
 
The process for moving ILITs from your bank to Citadel involves a few steps. After a decision is made to engage with Citadel, a thorough review of each ILIT is performed by Citadel and NITC staff to ensure acceptability and transferability. Subsequent to this review and an audit of applicable state laws pertaining to trusts, a strategy is formed between Citadel and the participating bank. This strategy maps out the steps involved in order to transfer each ILIT to Citadel management. Once the transfer has occurred, Citadel is responsible for all actions involved with management of the ILIT and analysis of the life insurance policies contained therein.
 
A2:   As it relates to National Independent Trust Company: The principals of NITC have operated in an independent trust company environment for more than seventeen years. NITC utilizes an existing framework that includes a charter from the Office of the Comptroller of the Currency and the requisite regulatory capital. NITC acts as the fiduciary and managing body for its divisions, which provide trust services to their client base.
 
Enhancing profitability is an important issue for trust service providers. NITC's support center, which includes its staff, technology, and facilities, provides regulatory compliance, internal audit functions, trust accounting operations services, technology systems and support to dramatically reduce the cost and investment required for those functions. Through an allocation of costs related to NITC's Service Center, Citadel Trust Company benefits from the resources of NITC.
 
 
Q:   What is Citadel/NITC's primary business model?
 
A:   Centralized operations supporting localized client servicing is the primary business model of Citadel and NITC. The Service Center of NITC is responsible for functioning as cost effective and efficiently as possible. All individual client servicing and interaction is performed on a 'local' basis by Citadel. This ensures that the professional serving the client is able to focus his attention on serving the client.
 
 
Q:   What are examples of ILIT client servicing?
 
A:   Citadel services its clients who have developed a trust relationship through face to face meetings in their locality. Many clients have a relationship with the trust company that requires less in-person contact. In transferring a book of business, we have options including opening a retail location in a particular state if the number of ILITs suggests such an action, or managing the trust relationship out of Citadel's main office in St. Louis, MO.
 
 
Q:   Do you support other models?
 
A:   Yes. The principals of Citadel and NITC are business people in the trust industry. Our purpose is to find a solution for situations that make business sense for all. Numerous groups have expressed a desire to divest themselves of the liability associated with ILITs. Given the varied situation for each bank, we are committed to finding a solution that works for your bank and for Citadel Trust Company, a division of NITC.
 
 
Q:   What is the basic structure of Citadel Trust Company, a division of NITC?
 
A:   Citadel Trust Company is a division of NITC and therefore has all of the powers of a national trust company. National Independent Trust Company (NITC) is an existing, fully operational independent trust company chartered and regulated by the Office of the Comptroller of the Currency (OCC).
 
 
Regulatory
 
Q:   What is the regulatory structure for Citadel Trust Company, a division of NITC?
 
A:   Citadel Trust Company, a division of NITC is a limited purpose (trust only) national bank chartered by the Office of the Comptroller of the Currency ('OCC'). The OCC is the primary regulator of national banks. NITC obtained its national charter in November 2000 by converting its state charter, formerly The Trust Company of Louisiana, based in Ruston, Louisiana.
 
The Southern District of the OCC based in Dallas, TX regulates NITC.
 
Periodic on-site examinations are conducted by staff of the OCC both at the main office and at the division offices.
 
 
Q:   How are examinations, audits, compliance matters, etc. handled?
 
A:   The NITC Board is responsible for all matters concerning the activities of NITC and its divisions. NITC maintains a compliance department that develops policies and procedures for conducting the business of operational rules and procedures. NITC maintains an internal audit department that has responsibility for conducting audits to verify compliance with those policies and procedures.
 
 
Trustee Issues
 
Q:   Who is the trustee of the client relationships?
 
A:   NITC is technically the trustee of all Citadel trust client relationships. However, NITC is permitted to conduct trust activities under assumed business names. This allows Citadel Trust Company to utilize its expertise in life insurance analysis and ILIT management in local markets while complying with trustee laws. The marketing focus and client interactions, including periodic client statements, "Crummey" notices, premium collection notices or other client interactions refer to the Citadel Trust Company.
 
 
Q:   If NITC is the trustee, who has responsibility for accepting accounts, setting fees and determining insurance due diligence policy, etc.?
 
A:   NITC provides broad guidance for appropriate policies and procedures in running its trust business. Utilizing NITC's established parameters, Citadel submits ILIT accounts, fees schedules, and life insurance due diligence for approval at regularly scheduled weekly and monthly committee meetings.
 
 
Managing Irrevocable Life Insurance Trusts (ILITs)
 
Q:   What ILIT services are offered by Citadel Trust Company?
 
A:   Citadel Trust Company will:
  • Perform a comprehensive review of the trust documents to ascertain transferability
  • Coordinate and implement the campaign to transfer the ILITs to Citadel
  • Provide a specialized national management structure in order to effectively incorporate all of your bank's ILITs
  • Transition your bank's ILITs onto the Citadel/NITC administrative system
  • Perform a pre-acceptance & annual review of the insurance carrier
  • Perform ongoing performance reviews of the insurance policy
  • Manage annual contributions & premium payment, performance reviews, and "Crummey" notices
  • Maintain account status
  • Prepare all necessary trust income tax returns
  • Manage assets of variable universal life insurance policies in accordance with the trust documents
  • Citadel Trust will manage all aspects of the ILIT administration

Q:   How are these services managed?
 
A:   Citadel and NITC are structured to accommodate a full array of services. The relationship and life insurance expertise is managed 'locally' through Citadel and the administration of the ILIT is managed nationally through NITC.
 
 
Operations
 
Q:   What trust accounting system is utilized and how does that work?
 
A:   NITC uses the Northern Trust/FITEC TrustRite accounting system. Divisions connect to the Service Center through an authorized Citrix connection via the internet. Division offices have full access to client information and management reports and are able to access the trust accounting system as if the operations staff were located just down the hall.
 
 
Q:   What other significant features does TrustRite provide?
 
A:   TrustRite provides real-time accounting and client access to statements including assets and transactions via the internet. This enables clients, outside advisors and others to access client account information on a password-protected basis. In addition, TrustRite provides download capabilities to portfolio management systems like Centerpiece that several divisions currently utilize.
 
 
Q:   How is account reporting handled?
 
A:   Trust clients typically only receive one statement of their account - from Citadel Trust Company. This report includes all account assets held for the benefit of the client without regard to custody situs or type of client asset. This eliminates the separate reporting often required by non-trust entities. If hardcopy statements are requested, monthly, quarterly or annual statements can be selected with most ILITs generally requesting annual statements due to the limited activity.
 
 
Q:   Are there any restrictions on where Citadel Trust can open offices?
 
A:   The OCC has issued a regulation (12 CFR 9.7) defining the permitted multi-state fiduciary activities of national banks and trust companies. There are certain requirements of the various states to which Citadel and NITC are subject. These vary from state to state. Generally, Citadel Trust, as a division of NITC under the OCC's regulation, can open an office in any state.
 
 
Q:   What laws apply to Citadel Trust / NITC's activities?
 
A:   As an entity governed by the OCC, federal law applies to most aspects of NITC's business. State trust law applies, however, to any trust administrative issues for trusts with a situs in that particular state. NITC must also comply with any state laws requiring an indemnity deposit from trust companies.
 
 
Q:   What insurance coverage is provided?
 
A:   Citadel Trust & NITC has insurance policies providing errors and omissions coverage for directors and officers, a blanket bond, fiduciary liability coverage, certain coverage for ERISA plans and other retirement account administration. Other coverage including property and casualty insurance, and workers compensation are also maintained.
 
 


Welcome
 
A Letter to Welcome You...
 
Contact Information
 
8630 Delmar Blvd.
Suite 110
St. Louis, MO   63124
 
Phone: 314-997-1110
Toll Free: 800-332-2963
Fax: 314-442-0070
 
info@citadeltrust.com

 


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