ISA -Appointee

Being an appointee for benefit purposes is a specific role to do with claiming and managing welfare benefits on behalf of another person and reporting change of circumstances etc.

Part of this role would be to open a bank account to receive benefits which you would normally do in your own name and manage on behalf of your son in this case.

I can understand how you might want to open an ISA in your son's name as part of managing his benefits.

I am not sure if there is a requirement or expectation for providers to accept the BF57 to enable an ISA to be opened.

However DWP guidance indicates that it is up to the provider to decide whether they will allow you to open an ISA for your son using the BF57 only. My logic here is that an ISA is an individual account (i.e. in the name of your son here) and the guidance talks about opening an account in your son's name only been possible if the provider 'gives its approval'.

The guidance notes for ISA managers are a bit vague here (see para 5.24 onwards) as they don't specifically mention appointees. Para 5.27 suggests that it is allowable in this case for you (as mother) to open an ISA for your son, in your son's name, if the disability is a mental health disability.

So looks like Hargreaves Lansdown are right and Virgin Money are wrong to say HL have breached regulations. However Virgin Money are probably within their rights to not allow you to open an ISA for your son.