This is our response to your December 2, 1998, memorandum requesting a formal legal
opinion from each Regional Chief Counsel on a State-by-State basis addressing specific
issues related to the purchase of property by representative payees on behalf of minor
children. The Associate Commissioner, Office of Program Benefits, asked that we address
the following issues:
* Does the State permit a minor to hold title to real estate or personal property
such as an automobile?
* If so, are there any restrictions as to the age of the minor or the types of property
that can be held?
* Are there any specific requirements on how the property should/must be titled to
show the minor as the titleholder?
* If a State does not permit a minor to hold title to property, or does not permit
the property to be titled/registered in the minor's name, what is the preferred method(s)
of titling the property to reflect or protect the minor's interest in the property
and satisfy SSA's regulatory requirements?
It is our legal opinion that under the laws of Tennessee there are no particular requirements
or prohibitions as to the manner of holding title to either real or personal property