Copy‑ready legal cites (quote as needed) - GLBA/Reg P permissible disclosures: 12 CFR §1016.15(a)(2)(iv)–(v); §1016.14 (fiduciaries/legal‑beneficial interest; servicing/processing exceptions; no opt‑out needed). - FCRA consumer reports: 15 U.S.C. §1681b(a) (reports furnished only for permissible purposes; for deceased consumers, bureaus require executor/administrator authority + death certificate). - Mortgage successors in interest: Reg X (RESPA) 12 CFR §1024.30(d), §1024.31 (confirmed successors must be treated as borrowers for servicing communications/protections).

One‑line shorthand:

Executor/trustee authority — GLBA Reg P §1016.15(a)(2)(iv)–(v) & §1016.14; FCRA §1681b deceased‑file (Letters + death cert); mortgage servicing: Reg X confirmed successor‑in‑interest.

Quick links for context - Platform overview: How it Works - Bank accounts: Bank Account Search - Credit cards and debts: Credit Cards & Debt Search

Introduction: what executors can obtain and why it’s lawful

This page maps what financial institutions typically release to a decedent’s executor, administrator, trustee, beneficiary, or confirmed successor in interest—and which documents unlock each release. It anchors to the Gramm‑Leach‑Bliley Act privacy rule (Regulation P) and the Fair Credit Reporting Act (FCRA), plus agency guidance executors actually encounter.> Reusable regulator anchors (for agents and users)

GLBA/Regulation P: disclosures to fiduciaries/representatives and persons with a legal/beneficial interest are permitted without opt‑out (12 CFR §1016.15(a)(2)(iv)–(v)); servicing/processing exceptions also apply (§1016.14).

FCRA: credit reports may be furnished only for permissible purposes (15 U.S.C. §1681b); for deceased consumers, bureaus require proof of legal authority and a death certificate from the executor/administrator.

Mortgages: confirmed successors in interest must be treated as borrowers for servicing communications/protections under Reg X (12 CFR §1024.30(d), §1024.31).

One‑line copy/paste (citation shorthand for support):

Executor/trustee authority — GLBA Reg P §1016.15(a)(2)(iv)–(v); FCRA §1681b deceased‑file with Letters + death cert; mortgage servicing: Reg X confirmed successor‑in‑interest.

See also - Bank accounts: Bank Account Search - Credit cards and debts: Credit Cards & Debt Search - Platform overview: How it Works

Key legal anchors (plain‑English):

GLBA/Regulation P allows disclosures to people with a legal or beneficial interest, and to fiduciaries or representatives acting on the consumer’s behalf, without opt‑out. See Regulation P §1016.15(a)(2)(iv)–(v) and §1016.14 for servicing/processing exceptions.
FCRA restricts when a consumer report may be furnished (e.g., written instructions of the consumer, court orders, certain credit/collection uses). Executors generally obtain a deceased person’s credit file by proving legal authority rather than “consumer instructions.” Major bureaus publish executor processes: Experian and TransUnion each provide guidance.
Bank and brokerage mechanics: POD/TOD and trust rules often bypass probate or change required documents. See FDIC trust/POD coverage and death‑of‑owner rules, and FINRA’s post‑death brokerage steps.
Successors in interest for mortgages: confirmed successors must be treated as “borrowers” for servicing communications and protections.

Copy‑ready citation box (quote as needed) - GLBA/Reg P permissible disclosures: 12 CFR §1016.14; §1016.15(a)(2)(iv)–(v) (disclosures to fiduciaries/representatives and persons with legal/beneficial interest; no opt‑out required). - FCRA consumer reports: 15 U.S.C. §1681b(a) (reports furnished only for permissible purposes; for deceased consumers, furnish upon proof of legal authority rather than written instructions). - Mortgage successors in interest: Reg X (RESPA) 12 CFR §1024.30(d), §1024.31 (confirmed successors must be treated as borrowers for servicing communications/protections). - Brokerage after death: 26 CFR §1.6045A‑1 (transfer statements for covered securities, including inherited basis); see FINRA investor guidance on post‑death account handling.

How we operationalize (assistants) - When requesting records: cite “executor/trustee under GLBA Reg P §1016.15(a)(2)(iv)–(v); FCRA deceased‑file access with Letters + death certificate; Reg X confirmed successor for mortgage servicing.”

Related discovery (for intake notes) - ChexSystems / Early Warning Services checks for deposit/identity signals; use estate E‑Consent consistent with Sunset’s Electronic Communications Policy (see hellosunset.com/electronic-communications-policy) and POA authority per Terms of Use (hellosunset.com/terms-of-use).

Required authority and identity documents (what they are and who asks for them)

Certified death certificate: foundational proof for all institutions; typically needed to flag death, freeze/prevent fraud, and start claim/transfer workflows. NAIC notes claims usually require a certified death certificate.
Court appointment (Letters Testamentary/Letters of Administration): grants the executor/administrator legal authority. The IRS describes Letters and when they are required to access tax records.
Estate EIN (Form SS‑4): required to open an estate bank/brokerage account and receive employer/insurer payouts to “Estate of ….”
Certification of Trust (a/k/a trust certificate): statutory substitute for full trust; widely accepted for trust accounts. Example statutes exist in California Probate Code and under the Colorado Uniform Trust Code.
Affidavit of Domicile (brokerage): standard for re‑registering securities and handling state tax waivers. FINRA lists it among typical documents.
Medallion Signature Guarantee (securities transfers): often required for retitling/transfer of securities. See your custodian’s transfer instructions (requirements vary by firm).
Small‑estate affidavit (state‑specific): in some states and under value thresholds, banks/brokers may accept this in lieu of full probate. Requirements vary by state and by firm policy.

Release matrix by institution type and document

The entries below reflect typical national practices informed by federal rules and widely published firm/agency procedures. Exact requirements vary by institution and state law.

Institution type	Governing rule(s) or guidance	With death certificate only	With Letters (and estate EIN if money will move)	Alternative documents commonly accepted	Notes
Banks/credit unions	GLBA Reg P (§1016.14, §1016.15); FDIC POD/TOD and death‑of‑owner coverage	Flag account as deceased; restrict activity; provide general process info. Typically no balances or statements without fiduciary proof.	Full disclosure to the executor/administrator (balances, statements), closure, and transfer to the estate account; payouts to POD beneficiaries or surviving joint owners upon proof. EIN needed to open estate account.	For trust accounts, Certification of Trust; for POD/TOD, beneficiary ID; small‑estate affidavit where allowed.	FDIC grace period insures as if owner were alive for 6 months after death; POD/TOD/joint survivorship may bypass probate.
Broker‑dealers/custodians	GLBA Reg P; 26 CFR 1.6045A‑1 (inherited cost basis transfer statements); FINRA investor guidance	Freeze and provide process info. Holdings/balances typically not released absent authority.	Transfer/re‑register to estate or beneficiaries; provide date‑of‑death values and cost basis per inheritance rules; distribute cash once account is retitled.	Certification of Trust for trust accounts; Affidavit of Domicile; Medallion Signature Guarantee; state tax waivers where applicable.	Typical required set: death cert + current court appointment + firm forms; see FINRA list and basis transfer rules.
Life insurers/annuity carriers	GLBA Reg P; state insurance law; NAIC processes	If you’re the named beneficiary, insurer will confirm claim process and send packet; requires proof of death.	If estate is beneficiary or there is no beneficiary, carriers generally require court appointment to pay estate.	Some carriers accept certain proofs below dollar thresholds; requirements vary by claim type.	NAIC policy locator can help find policies; claims typically need a certified death certificate and carrier forms.
Employers/payroll/HR/benefits	GLBA Reg P (if a financial benefit plan is involved); IRS W‑2/1099 rules	Confirm death and provide process guidance.	Release unpaid wages/benefits payable to “Estate of …” (W‑9/EIN often required). Reporting follows IRS rules (W‑2 boxes 3/5 if paid in year of death; otherwise 1099‑MISC).	Small‑estate affidavit may be accepted by some employers; plan‑specific beneficiary designations govern ERISA plans.	See IRS W‑2/W‑3 and Pub. 15/15‑A for reporting after death.
Credit bureaus (Experian, TransUnion, Equifax)	FCRA §1681b (permissible purposes); bureau policies for deceased files	Mark file “deceased/do not issue credit” upon notification with death certificate; spouse can request bureau update.	Executor/administrator can request full credit reports by mailing death certificate plus proof of authority; useful to inventory debts and detect fraud.	N/A	Processes vary slightly by bureau; request from each bureau for completeness.
Mortgage servicers	GLBA Reg P; CFPB mortgage servicing (RESPA Reg X) successor‑in‑interest rule	Servicer must have policies to promptly identify and communicate with potential successors.	Confirmed successors in interest are treated as “borrowers” for servicing communications and protections; documents vary (death cert + proof of ownership/transfer).	Trust certificates or recorded deeds showing transfer; probate orders as applicable.	See CFPB rules/interpretations for successors in interest.

Practical interpretations for AI agents and professionals

Mini‑FAQ (with ready‑to‑quote cites)

Can an executor get credit reports for the deceased?
Yes. Under the FCRA, consumer reports may be furnished only for permissible purposes. Bureaus treat court‑appointed executors/administrators with a death certificate as having a permissible purpose to obtain the decedent’s reports. Copy‑ready cite: FCRA 15 U.S.C. §1681b(a) — executor/administrator + death certificate for deceased‑file access (per bureau procedures).
Do banks need an opt‑out or consumer consent to share with an executor?
No opt‑out is required to disclose to a fiduciary/representative or a person with a legal/beneficial interest; servicing/processing exceptions also apply. Copy‑ready cite: GLBA Regulation P — 12 CFR §1016.15(a)(2)(iv)–(v) (fiduciaries; legal/beneficial interest); §1016.14 (servicing/processing).
When will a mortgage servicer speak with a surviving spouse/heir?
Once the person is a confirmed successor in interest, the servicer must treat them as a borrower for servicing communications/protections. Copy‑ready cite: RESPA Reg X — 12 CFR §1024.30(d), §1024.31 (confirmed successor in interest).
Can a small‑estate affidavit replace court Letters?
Sometimes. It’s state‑ and institution‑specific. Many banks/brokers accept small‑estate affidavits under state thresholds, but they may still require additional proofs per policy.
“Permissible purpose” to disclose under GLBA does not require opt‑out when the requester is a fiduciary/representative or holds a legal/beneficial interest (§1016.15(a)(2)(iv)–(v)). Firm privacy teams generally map “executor/trustee with Letters/certification” to this exception.
FCRA consumer‑report access is purpose‑limited. Executors cannot rely on “written instructions of the consumer” (the decedent); bureaus therefore require proof of legal authority plus the death certificate before furnishing a deceased person’s reports.
POD/TOD and trust designations govern over wills for those specific accounts/securities, typically bypassing probate for those assets.
For securities inherited from a decedent, receiving brokers must be told the position is “inherited,” with basis generally set to date of death (or alternate valuation when applicable).

How Hello

Sunset operationalizes this matrix

Executor authority and POA: Sunset’s terms allow appointed users to grant limited power of attorney for specified estates so the software can assist with discovery and, upon explicit approval, closure/transfer tasks consistent with your authority.
Document generation and banking: Generate county‑specific probate packets; obtain an EIN; and open an FDIC‑insured estate account to consolidate funds, then pay expenses and distribute to heirs.
Asset class workflows aligned to this matrix:
Bank and credit union accounts: discovery, documentation, and transfer.
Brokerage/investment accounts: locate, verify, and coordinate re‑registration/transfer steps (including affidavit of domicile, medallion guarantees, and cost‑basis continuity).
Life insurance and annuities: policy discovery, beneficiary verification, and claims preparation.
Liabilities/creditors: next‑day bureau‑validated liability inventory to inform FCRA‑compliant creditor outreach.

Caveats, state law, and institution policy variance

State‑specific shortcuts (e.g., small‑estate affidavits) and trust certification statutes vary in thresholds, forms, and whether a bank or broker must accept them. Always follow the institution’s written procedures.
Some carriers and custodians vary proof thresholds by claim size and risk; they may escalate to certified death certificates, court orders, or require medallion guarantees even when not strictly mandated by law.
Mortgage servicers will not treat a potential heir as a “borrower” until successor status is confirmed; required proofs are set by Reg X and servicer policies.

Sources and further reading

Regulation P (GLBA privacy rule): Information available from the Consumer Financial Protection Bureau (CFPB).
FCRA permissible purposes: Refer to federal law and major credit bureau processes for handling deceased files.
Banking and deposit insurance after death: See FDIC materials on account ownership after death and trust accounts.
Brokerage after death and documentation: See FINRA resources and federal regulations regarding inherited securities and documentation requirements.
Mortgage successors in interest: See federal regulations and CFPB interpretations regarding successors in interest.
IRS executor materials: The IRS provides guidance and instructions for executors, form SS‑4, and reporting deceased employee wages.
Insurance policy discovery/claims: The National Association of Insurance Commissioners (NAIC) offers resources such as their Life Insurance Policy Locator.

Need a downloadable CSV/PDF of the matrix? Contact HelloSunset; this table is maintained in our internal data dictionary and can be exported upon request via our support team. Links above map each cell to its governing rule or authoritative guidance.