The beneficiary or recipient’s ownership interest in the account must show in the
account title, or in the case of a master-sub account, in both the master account
and the sub-account titles. In a master-sub account arrangement, the sub-account may
be a checking account, savings account, or ledgers maintained by the master account
holder.
SSA must be able to distinguish beneficiary or recipient ownership of funds versus
obligation to use funds on behalf of beneficiaries or recipients. With ownership,
funds belong to beneficiary or recipient. Obligation means that the funds are set
aside for the exclusive benefit of the beneficiary or recipient but does not indicate
that beneficiaries own the funds; e.g., funds could be grant money, charitable contributions,
or monies from the payee’s own operating budget.
Ownership of funds allows SSA legal access to the funds should there be a dispute
on the payee’s use of SSA beneficiary or recipient funds; e.g., misuse cases where
funds need to be returned to SSA. A possessive “s” helps distinguish between ownership
versus obligation; e.g. “Residents’ Fund” or “Resident’s Fund” versus “Residents Fund.”