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gettechnical inc 1 Opening Accounts for Nonprofit Organizations Supplement 2015 Presented by: Gettechnical, Inc. Phone: (800) 354-3051 [email protected] www.gettechnicalinc.com

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Page 1: Opening Accounts for Nonprofit Organizations Supplement Opening Accounts for Nonprofit... · nonprofit organization that is independent from government. NGOs can range from large

gettechnical inc 1

Opening Accounts for Nonprofit Organizations

Supplement

2015 Presented by: Gettechnical, Inc. Phone: (800) 354-3051 [email protected] www.gettechnicalinc.com

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The material used in this text has been drawn from sources believed to be reliable. Every effort has been made to assure the accuracy of the material; however, the accuracy of this information is not guaranteed. The laws are often changed without prior notice from the government. The OPENING ACCOUNTS FOR NONPROFIT ORGANIZATIONS SUPPLEMENT manual is sold with the understanding that the publisher and the editor are not engaging in the practice of law or accounting. We are not responsible for the actions of your company's employees. The text is designed to address most deposit account documentation issues. However, you will wish to consult your attorney when you are unsure of an answer. Published by: gettechnical inc 800 E Morris Hill Rd Covington, VA 24426 Office: 1-800-354-3051 E-mail: [email protected] Website: www.gettechnicalinc.com All rights reserved. This material may not be reproduced in whole or in part in any form or by any means without written permission from the publisher. Printed in the United States of America. sm2015.06.26

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TABLE OF CONTENTS

BSA EXAM......................................................................................................................................... 5

EXAM MANUAL, EXPANDED EXAMINATION OVERVIEW AND PROCEDURES FOR PERSONS AND ENTITIES: NONGOVERNMENTAL ORGANIZATIONS AND CHARITIES - OVERVIEW ................................................................................................................................................ 6 EXAMINATION PROCEDURES FOR NONGOVERNMENTAL ORGANIZATIONS AND CHARITIES ................................................................................................................................................ 8 CHECKLIST FOR NONGOVERNMENTAL ORGAONIZATOINS AND CHARITIES......................... 9

FORMS ............................................................................................................................................. 11

INSTRUCTIONS FOR W-9 (DEC 2014) .................................................................................................. 16 FORM: W-8BEN-E CERTIFICATE OF STATUS OF BENEFICIAL OWNER FOR UNITED STATES TAX WITHHOLDING AND REPORTING (ENTITIES) (FEB 2014) ..................................... 20 FORM: SS-4 APPLICATION FOR EMPLOYER IDENTIFICATION NUMBER (EIN) (JANUARY 2010) .......................................................................................................................................................... 28 WORKSHEET ON ENTITY ACCOUNTS .............................................................................................. 30

NON PROFIT ORGANISATION ACCONS ................................................................................ 34

OVERVIEW: FLOWCHART NONPROFIT ............................................................................................ 35 NONPROFIT CORPORATIONS ............................................................................................................. 36 TABLE: NONPROFIT CORPORATIONS .............................................................................................. 37 CHECKLIST FOR NONPROFIT CORPORATIONS .............................................................................. 40 LAW: NONPROFIT CORPORATIONS ................................................................................................. 41 FORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION .................................................... 42 TABLE: FORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION..................................... 43 CHECKLIST FOR FORMAL NONPROFIT ASSOCIATION................................................................. 45 FLOWCHART: FORMAL NONPROFIT OR UNINCORPORATED ORGANIZATION ..................... 46 INFORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION ................................................ 47 TABLE: INFORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION ................................ 48 CHECKLIST FOR INFORMAL NONPROFIT ASSOCIATION ............................................................ 50 HOMEOWNERS’ ASSOCIATION .......................................................................................................... 51 TABLE: HOMEOWNERS’ ASSOCIATION .......................................................................................... 52 CHECKLIST FOR HOMEOWNERS’ ASSOCIATION .......................................................................... 54 NEIGHBORHOOD ASSOCIATIONS ..................................................................................................... 55 TABLE: NEIGHBORHOOD ASSOCIATION ........................................................................................ 56 CHECKLIST FOR NEIGHBORHOOD ASSOCIATION ........................................................................ 58 BENEFIT, TRAGEDY OR MEMORIAL ACCOUNTS ........................................................................... 59 TABLE: BENEFIT, TRAGEDY OR MEMORIAL ACCOUNTS ........................................................... 60 CHECKLIST FOR BENEFIT, TRAGEDY OR MEMORIAL ACCOUNTS ........................................... 62 CAMPAIGN ACCOUNTS ....................................................................................................................... 63 TABLE: CAMPAIGN ACCOUNTS ........................................................................................................ 64 CHECKLIST FOR CAMPAIGN ACCOUNTS ........................................................................................ 66 LAW: CAMPAIGN FINANCE ................................................................................................................ 67 PUBLIC FUND ACCOUNTS ................................................................................................................... 72 TABLE: PUBLIC FUNDS ....................................................................................................................... 73 THESE AREAS MUST BE ADDRESSED IN YOUR POLICY .............................................................. 75

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SUMMARY OF DEPOSIT ACCOUNTS ..................................................................................... 77

APPENDIX ....................................................................................................................................... 82

FDIC: UNINCORPORATED ASSOCIATIONS ...................................................................................... 83 OFFICE OF FOREIGN ASSETS CONTROL – FREQUENTLY ASKED QUESTIONS ........................ 85 IRS WEB SITE AND EINS ....................................................................................................................... 86

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BSA Exam

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EXAM MANUAL, EXPANDED EXAMINATION OVERVIEW AND PROCEDURES FOR PERSONS AND ENTITIES: NONGOVERNMENTAL ORGANIZATIONS AND CHARITIES - OVERVIEW

Objective. Assess the adequacy of the bank’s systems to manage the risks associated with accounts of non-governmental organizations (NGOs) and charities, and management’s ability to implement effective due diligence, monitoring, and reporting systems.

NGOs are private nonprofit organizations that pursue activities intended to serve the public good. NGOs may provide basic social services, work to relieve suffering, promote the interests of the poor, bring citizen concerns to governments, encourage political participation, protect the environment, or undertake community development to serve the needs of citizens, organizations, or groups in one or more of the communities that the NGO operates. An NGO can be any nonprofit organization that is independent from government.

NGOs can range from large regional, national, or international charities to community-based self-help groups. NGOs also include research institutes, churches, professional associations, and lobby groups. NGOs typically depend, in whole or in part, on charitable donations and voluntary service for support.

Risk Factors Because NGOs can be used to obtain funds for charitable organizations, the flow of funds both into and out of the NGO can be complex, making them susceptible to abuse by money launderers and terrorists. The U.S. Treasury issued guidelines to assist charities in adopting practices to reduce the risk of terrorist financing or abuse.1 Risk Mitigation To assess the risk of NGO customers, a bank should conduct adequate due diligence on the organization. In addition to required CIP information, due diligence for NGOs should focus on other aspects of the organization, such as the following: Purpose and objectives of their stated activities.

Geographic locations served (including headquarters and operational areas).

Organizational structure.

Donor and volunteer base.

Funding and disbursement criteria (including basic beneficiary information).

Recordkeeping requirements.

1 Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities, September 2006, is available at www.treasury.gov/offices/enforcement/key-issues/protecting/index.shtml.

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Its affiliation with other NGOs, governments, or groups.

Internal controls and audits.

For accounts that bank management considers to be higher risk, stringent documentation, verification, and transaction monitoring procedures should be established. NGO accounts that are at higher risk for BSA/AML concerns include those operating or providing services internationally, conducting unusual or suspicious activities, or lacking proper documentation. EDD for these accounts should include: Evaluating the principals.

Obtaining and reviewing the financial statements and audits.

Verifying the source and use of funds.

Evaluating large contributors or grantors of the NGO.

Conducting reference checks.

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EXAMINATION PROCEDURES FOR NONGOVERNMENTAL ORGANIZATIONS AND CHARITIES

Objective. Assess the adequacy of the bank’s systems to manage the risks associated with accounts of non-governmental organizations (NGOs) and charities, and management’s ability to implement effective due diligence, monitoring, and reporting systems.

1. Review the policies, procedures, and processes related to NGOs. Evaluate the adequacy of the policies, procedures, and processes given the bank’s NGO accounts and the risks they represent. Assess whether the controls are adequate to reasonably protect the bank from money laundering and terrorist financing.

2. From a review of MIS and internal risk rating factors, determine whether the bank effectively identifies and monitors higher-risk NGO accounts.

3. Determine whether the bank’s system for monitoring NGO accounts for suspicious activities, and for reporting of suspicious activities, is adequate given the bank’s size, complexity, location, and types of customer relationships.

4. If appropriate, refer to the core examination procedures, “Office of Foreign Assets Control,” for guidance.

Transaction Testing

5. On the basis of the bank’s risk assessment, its NGO and charity accounts, as well as prior examination and audit reports, select a sample of higher-risk NGO accounts. From the sample selected, perform the following examination procedures:

Review account opening documentation and ongoing due diligence information. Review account statements and, as necessary, specific transaction details. Compare expected transactions with actual activity. Determine whether actual activity is consistent with the nature of the customer’s business. Identify any unusual or suspicious activity. 6. On the basis of examination procedures completed, including transaction testing, form a conclusion about the adequacy of policies, procedures, and processes associated with NGO accounts.

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CHECKLIST FOR NONGOVERNMENTAL ORGAONIZATOINS AND CHARITIES

CHECKLIST FOR NONGOVERNMENTAL ORGANIZATIONS AND CHARITIES

___ Purpose and objectives of their stated activities

___ The geographic locations served (including headquarters and operational areas)

___ The organizational structure

___ The donor and volunteer base

___ Funding and disbursement criteria (including basic beneficiary information)

___ Recordkeeping requirements

___ Its affiliation with other NGOs, governments, or groups

___ Internal controls and audits

___ Evaluating the principals

___ Obtaining and reviewing the financial statements and audits

___ Verifying the source and use of funds

___ Evaluating large contributors or grantors of the NGO

___ Conducting reference checks

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WARNING THESE ARE REQUEST LETTER ITEMS! ___ Make available copies of policies, procedures, and processes related to nongovernmental organizations and charities. ___ List of non-governmental organizations and charities, particularly those that the bank the bank has designated as high risk. This list should include average account balances and the average number and dollar volume of transactions. ___ List of non-governmental organizations involved in high-risk geographic locations.

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Forms

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REQUEST FOR TAXPAYER IDENTIFICATION NUMBER AND CERTIFICATION (FORM W-9) (DEC 2014)

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INSTRUCTIONS FOR W-9 (Dec 2014)

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FORM: W-8BEN-E CERTIFICATE OF STATUS OF BENEFICIAL OWNER FOR UNITED STATES TAX WITHHOLDING AND REPORTING (ENTITIES) (FEB 2014)

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FORM: SS-4 APPLICATION FOR EMPLOYER IDENTIFICATION NUMBER (EIN) (JANUARY 2010)

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WORKSHEET ON ENTITY ACCOUNTS

New Existing Exempt

CIP PROFILE BUSINESS ACCOUNTS COMPLETE CIP PROFILE

IF YOUR BANK REQUIRES INFORMATION ON ALL

SIGNERS THEN USE PERSONAL SHEET ABOVE

SECTION ONE: INFORMATION BUSINESS NAME OR DBA NAME_________________________________________________________________ (As it appears on government issued document) PHYSICAL ADDRESS_________________________________________________________________________ ADDRESS LINE 2 ___________________________________________________________ APT/STE _______ CELL PHONE # ________________________ TELEPHONE #____________________________ SSN OR EIN ____________________________ Sole Proprietors and Single member LLCs may use SSN of the owner

SECTION TWO: DOCUMENTS � Nonprofit

organization or club

Charter, By-laws, minutes Otherwise have to identify all signers

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SECTION THREE: DOCUMENTS

Nondocumentary verification

Check systems, telecheck, credit reports Customer telephone call Letter of welcome Site visit Previous financial institution reference Verification of employment whitepages.com google.com Secretary of State- online at [your state]

Regulation CC Hold

Yes/No Circle One

OFAC Check

Yes/No Circle One If match, false positive or complete match Results:_____________________________

Resolve conflict in documents:

Additional Comments:

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SECTION FOUR: QUESTIONS

Type of customer: New Existing customer adding new service

Account opening method: In person all parties present In person, less than all parties present Mail Telephone Email, website

Type of person: US Person Non US person

Type of deposit: Cash On us transfer or

check Payroll check

Government

Check Cashier’s check Wire Foreign Fund

Type of business: Buying or selling motor vehicles of any kind, vessels,

aircraft, farm equipment, or mobile homes Practicing law Accounting Practicing medicine Chartering or operating ships, buses, or aircraft Other___________________________________________ Location of customer:

HIDT Parish/County Non HIDT Parish/County

What brought you to our bank? Product Relationship with banker Location Dissatisfied with current bank Other____________________

Do you have any deposits come in automatically? Payroll Operating Account Other______________________

How close is your office? 1-5 miles 6-10 miles 11+ miles

Do you have any deposits come in automatically?

YES NO

Do you use automatic withdrawals? Sweep Accounts Utilities Other______________________

Do you plan to use the following: Internet banking ATM, Debit Cards Other branches? If so where____________________________ Wire services? If so where___________________________ Lending Safe Deposit Boxes ACH Lockbox

Do you know how many deposits you will make a month? 1-5 6-10 11 or more

Do you know how many checks or withdrawals you plan to make a month?

1-5 6-10 11 or more

Do you have any cash needs for our branch? YES If “yes”, how

much____________.

Does your company process internet gambling transactions? YES NO

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SECTION FIVE

What is the purpose of the organization?

Civic Benefit, Tragedy or Memorial Political Campaign Public Fund Other

What geographic locations are served?

County/Parish State United States International

How is your organization structured? Officers with regular meetings Board Steering Committee Other

Who is the volunteer base? Local individuals in county Statewide volunteers National volunteers International volunteers

Where does the funding come from? Local donations Statewide donations National donations International donations

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Non profit Organisation Accons

Overview: Flowchart Nonprofit Nonprofit Corporations

Formal Nonprofit or Unincorporated Associations Flowchart: Formal Nonprofit or Unincorporated Organization

Informal Nonprofit or Unincorporated Associations Benefit, Tragedy or Memorial Accounts

Campaign Accounts Public Fund Accounts

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OVERVIEW: FLOWCHART NONPROFIT

* All require bank resolution and signature cards. Public funds may or may not have resolution.

NONPROFIT ACCOUNTS

Nonprofit Corporations

Formal Nonprofit

Organizations

Informal Nonprofit

Organizations

Public Fund Accounts

Formal application

with secretary of state

EIN

Articles of Incorporation Certificate of Incorporation

Formal organization

with their organizing

body

EIN

By-laws, charters

Informally organized by

local community

people

EIN

No formal documentation.

Must ID the signers

Set up by law and

government

EIN

May have documents

depending on how organized

Tragedy and Benefit

Accounts

Usually informally

organized by local

community people

EIN

No formal documentation.

Must ID the signers

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NONPROFIT CORPORATIONS

1. Description A nonprofit corporation is formed when, in most states, Articles of Incorporation are filed with your government entity to approve the new business. Corporations doing business in more than one state must register as a "foreign corporation" in each state. The nonprofit corporation files documents with the county or state, depending on state law. Request the appropriate government issued documents. A corporation is a legal entity separate from its owners. The election of officers, usually contained in the minutes, is done at the first board meeting. The opening and closing of an account is authorized by the Board of Directors and carried out by the Corporate Secretary. The only additional documentation from normal corporations is the 501C Tax Determination Letter. [Note: information regarding your state’s statutes is available on our gettechnical website at https://gettechnicalinc.com/resources/state-specific-resources.] 2. Insurance Corporations are separately insured for $250,000.

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TABLE: NONPROFIT CORPORATIONS

Nonprofit Corporations

1. Required Information on Nonprofit Corporation:

(Before opening account)

Name Address Taxpayer identification— the account will

use the employer identification number of the corporation. See special rules for non U.S. Persons signers under CIP Overview.

2. IRS Reporting: Report in EIN of Corporation

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Nonprofit Corporations

3. Documentary Requirements: (Reasonable time after opening)

Valid identification on corporate secretary. This is a recommendation some banks require the CIP on all signers.

My bank does/does not require all signers to Complete CIP.

Government Issued Paperwork: Most states either have a certificate of incorporation or application stamped “filed” after approval.

IRS 501(c) Tax determination letter Minutes from Board Meeting: The customer

should provide an excerpt from the minutes of the last board meeting where officers were elected—specifically the Secretary of the corporation since this person must sign the resolution. Sometimes the minutes are built into the bank’s resolution.

Bank Provided Resolution: Provided by the bank for corporations signed by the secretary of the business. There may be other signers on the account. These signers may be changed at any time, provided the corporation provides new minutes, new resolution and new signature card.

Bank Provided Signature Card: Provided by the bank signed by those authorized in the resolution. It is the contract between the bank and the customer.

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Nonprofit Corporations

4. Suggested nondocumentary verification: (Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account

officer Third party verification Contact Secretary of State’s Office

5. Account Styling: Boy Scouts of America, Inc.

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance: Each corporation is separately insured for $250,000.

8. Miscellaneous: No PODs on Corporations.

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CHECKLIST FOR NONPROFIT CORPORATIONS

Checklist for Nonprofit Corporations

___ Required information on Corporation

___ Report to IRS in EIN of Corporation

___ Valid identification on Corporate Secretary or other signers as required by your CIP.

___ Government Issued Paperwork

___ IRS 501(c) Tax Determination Letter

___ Minutes from Board electing Secretary, if not in resolution

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Nondocumentary verification

___ Account Styling: Boy Scouts of America, Inc.

___ Account Ownership: Corporation

___ Government Lists

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LAW: NONPROFIT CORPORATIONS

See your state’s statutes regarding nonprofit corporations. [Note: the location of your state’s statutes can be found on our website https://gettechnicalinc.com/resources/state-specific-resources]

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FORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION

1. Description

Charitable Associations, nonprofit groups, school clubs or other unincorporated organizations are examples of this type of account. This category covers groups who open accounts for civic, community, political reasons and are not organized for profit. These groups such as Rotary, Lions Club, Kiwanis and many others do have organizing bodies and they apply for a Charter and establish By-Laws. Most of these organizations meet monthly and have formal structure and officers. It is easy to pass these accounts from year to year to the next set of officers as documented in the minutes. You will run CIP on the entity. If your bank requires identification on all signatories on accounts, then you will have to CIP the signers also.

2. Insurance

Nonprofit organizations are separately insured for $250,000.

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TABLE: FORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION

Formal Nonprofit or Unincorporated Association

1. Required Information: (Before opening account)

Name Address Taxpayer identification— the account will use the

employer identification number of organization.

2. IRS Reporting: Report in EIN of organization

3. Documentary Requirements: (Reasonable time after

opening)

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

My bank does/does not require CIP on all signers. Charter, By-laws or Letter of Purpose: Provided by

customer. Minutes of Meeting: Provided by customer

authorizing account opening and signatories. Bank Provided Resolution: Resolution authorizing

the account and who will sign. Bank Provided Signature Card: Contract between

bank and customer.

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Formal Nonprofit or Unincorporated Association

4. Suggested nondocumentary verification:

(Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account officer Third party verification Previous financial institution references

5. Account Styling: Name of organization Examples: Rotary Lions Club Kiwanis

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance: $250,000 per organization.

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CHECKLIST FOR FORMAL NONPROFIT ASSOCIATION

Checklist for Formal Nonprofit Association

___ Required information on nonprofit association

___ Valid identification on signers as required in your CIP

___ Charter, Bylaws

___ Minutes

___ Report to IRS in EIN of Association

___ Account Styling: Rotary Lions Club Kiwanis

___ Account Ownership: Nonprofit

___ Nondocumentary verification

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Government lists

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FLOWCHART: FORMAL NONPROFIT OR UNINCORPORATED ORGANIZATION

Documentation • Charters

• Bylaws

• Minutes

1

Resolution

Authorizes the Signature Card

_________

2

Signature Card Signed by those authorized on the resolution

3

Changes

• New Resolution • New Signature

Card • New Minutes

4

Person authorized by association in minutes

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INFORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION

1. Description

Charitable Associations, nonprofit groups, school clubs or other unincorporated organizations may be quite small. This category covers groups who open accounts for civic, community, political reasons and are not organized for profit. These can be the local softball, kickball, soccer, flower funds, coffee clutches and many other type of accounts

2. Insurance

Nonprofit organizations are separately insured for $250,000.

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TABLE: INFORMAL NONPROFIT OR UNINCORPORATED ASSOCIATION

Nonprofit or Unincorporated Association

1. Required Information: (Before opening account)

Name Address Taxpayer identification— the account will use the

employer identification number of organization.

2. IRS Reporting:

Report in EIN of organization

3. Documentary Requirements:

Valid identification on all persons opening the account. Since there will be no outside documents such as charters and by-laws. You will have to identify every signer on the account.

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

4. Suggested nondocumentary verification:

(Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account officer Third party verification Previous financial institution references

5. Account Styling: Name of organization

Examples: Trussville Little League Flower Fund Hunting Club 1975 Class Reunion

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Informal Nonprofit or Unincorporated Association

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance:

$250,000 per organization.

8. Miscellaneous: Some small organizations will not have outside documents. You will have to identify all signatories if your bank decides to open these accounts.

Do not set up as a personal account unless the SSN or the person on the account is signing. And the checks are coming in made out personally to that person.

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CHECKLIST FOR INFORMAL NONPROFIT ASSOCIATION

Checklist for Informal Nonprofit Association

___ Required information on nonprofit association

___ Valid identification on all signatories

___ Some banks have customer write a “Letter of Purpose”

___ Report to IRS in EIN of Association

___ Account Styling: Trussville Little League Flower Fund Hunting Club 1975 Class Reunion

___ Account Ownership: Nonprofit

___ Nondocumentary verification

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Government lists

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HOMEOWNERS’ ASSOCIATION

1. Description Source Wikipedia

In the United States, a homeowner association (or homeowners association) (HOA) is a corporation formed by a real estate developer for the purpose of marketing, managing, and selling of homes and lots in a residential subdivision. It grants the developer privileged voting rights in governing the association, while allowing the developer to exit financial and legal responsibility of the organization, typically by transferring ownership of the association to the homeowners after selling off a predetermined number of lots. Membership in the homeowners association by a residential buyer is typically a condition of purchase; a buyer isn't given an option to reject it. Most homeowner associations are incorporated, and are subject to state statutes that govern non-profit corporations and homeowner associations. State oversight of homeowner associations is minimal, and varies from state to state. Some states, such as Florida[1] and California,[citation needed] have a large body of homeowner association law, and some states, such as Massachusetts,[citation needed] have virtually no homeowner association law.

The fastest growing form of housing in the United States today is common-interest development (CID), a category that includes planned unit developments of single-family homes, condominiums, and cooperative apartments.[2] Since 1964, HOAs have become increasingly common in the United States. The Community Associations Institute trade association estimated that HOAs governed 24.8 million American homes and 62 million residents in 2010.[3]

2. Insurance

Nonprofit organizations are separately insured for $250,000.

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TABLE: HOMEOWNERS’ ASSOCIATION

Homeowners’ Association

1. Required Information: (Before opening account)

Name Address Taxpayer identification— the account will use the

employer identification number of organization.

2. IRS Reporting: Report in EIN of organization

3. Documentary Requirements:

(Reasonable time after opening)

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

My bank does/does not require CIP on all signers. Charter, By-laws or Letter of Purpose: Provided by

customer. Minutes of Meeting: Provided by customer

authorizing account opening and signatories. Bank Provided Resolution: Resolution authorizing

the account and who will sign. Bank Provided Signature Card: Contract between

bank and customer.

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Homeowners’ Association

4. Suggested nondocumentary verification: (Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account officer Third party verification Previous financial institution references

5. Account Styling: Name of organization Examples: River Ranch Aspen Highlands Homeowners’ Association

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance: $250,000 per organization.

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CHECKLIST FOR HOMEOWNERS’ ASSOCIATION

Checklist for Homeowners’ Association

___ Required information on nonprofit association

___ Valid identification on signers as required in your CIP

___ Charter, Bylaws

___ Minutes

___ Report to IRS in EIN of Association

___ Account Styling: Pelican Point Homeowners’ Association

___ Account Ownership: Nonprofit

___ Nondocumentary verification

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Government lists

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NEIGHBORHOOD ASSOCIATIONS

1. Description (Wikipedia)

A Neighborhood Association (NA) is a group of residents or property owners who advocate for or organize activities within a neighborhood. An association may have elected leaders and voluntary dues. Sometimes Neighborhood Associations are known as Property Owners Associations.

Some neighborhood associations in the United States are incorporated, may be recognized by the Internal Revenue Service as 501(c)(4) nonprofit organization, and may enjoy freedom from taxation from their home state.[1]

The term neighborhood association is sometimes incorrectly used instead of homeowners association (HOA). But neighborhood associations are not homeowners associations (HOA). An HOA is a group of property owners with the legal authority to enforce rules and regulations that focus on restrictions and building and safety issues. On the other hand, a neighborhood association is a group of neighbors and business owners who work together for changes and improvements such as neighborhood safety, beautification and social activities. They reinforce rules and regulations through education, peer pressure and by looking out for each other. Some key differences include: [2]

• HOA membership is mandatory generally through rules tied to the ownership of property like deed restrictions. Neighborhood association membership is voluntary or informal.

• HOAs often own and maintain common property, such as recreational facilities, parks, and roads, whereas neighborhood associations are focused on general advocacy and community events.

The rules for formation of a neighborhood association in the United States are sometimes regulated at the city or state level.

Neighborhood Councils within a city, whose officers are generally elected, are composed of various neighborhood associations and, as such, may be subject to limitations and special rules set up by the Council.

Neighborhood associations are more likely to be formed in older, established neighborhoods, especially those that that predates HOAs. HOAs are generally established at the time a residential neighborhood is built and sold. Sometimes older established neighborhoods form an HOA to help regulate rules and standards.

In some cases, neighborhood associations exist simultaneously with HOAs, and each may not encompass identical boundaries. In one example, newer neighborhoods built decades after the original, surrounding HOA-less neighborhood may have its own HOA but also be within the boundaries of a NA.

2. Insurance

Nonprofit organizations are separately insured for $250,000.

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TABLE: NEIGHBORHOOD ASSOCIATION

Neighborhood Association

8. Required Information: (Before opening account)

Name Address Taxpayer identification— the account will use the

employer identification number of organization.

9. IRS Reporting: Report in EIN of organization

10. Documentary Requirements:

(Reasonable time after opening)

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

My bank does/does not require CIP on all signers. Charter, By-laws or Letter of Purpose: Provided by

customer. Minutes of Meeting: Provided by customer

authorizing account opening and signatories. Bank Provided Resolution: Resolution authorizing

the account and who will sign. Bank Provided Signature Card: Contract between

bank and customer.

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Neighborhood Association

11. Suggested nondocumentary verification: (Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account officer Third party verification Previous financial institution references

12. Account Styling: Name of organization Examples: River Ranch Aspen Highlands Homeowners’ Association

13. Consult Government Lists: Section 326 List OFAC List

14. Insurance: $250,000 per organization.

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CHECKLIST FOR NEIGHBORHOOD ASSOCIATION

Checklist for Neighborhood Association Association

___ Required information on nonprofit association

___ Valid identification on signers as required in your CIP

___ Charter, Bylaws

___ Minutes

___ Report to IRS in EIN of Association

___ Account Styling: Woodlands Neighborhood Association

___ Account Ownership: Nonprofit

___ Nondocumentary verification

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Government lists

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BENEFIT, TRAGEDY OR MEMORIAL ACCOUNTS

1. Description

Benefit, Tragedy or Memorial accounts are usually the result of an event in the community that leaves people without resources. Hurricanes, fires, death and other events usually trigger this type of financial response from individuals trying to help. These are a type of nonprofit account and are not formally organized so should be treated like the informal nonprofit organizations.

2. Insurance

Nonprofit organizations are separately insured for $250,000.

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TABLE: BENEFIT, TRAGEDY OR MEMORIAL ACCOUNTS

Benefit, Tragedy or Memorial Accounts

1. Required Information: (Before opening account)

Name Address Taxpayer identification— the account will use the

employer identification number of organization.

2. IRS Reporting:

Report in EIN of organization

3. Documentary Requirements: (Reasonable time after

opening)

Valid identification on all persons opening the account. In CIP, if you cannot identify the entity, we identify the signers.

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

4. Suggested nondocumentary verification:

(Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account officer Third party verification Previous financial institution references

5. Account Styling: Name of organization Examples: Little Johnny Hospital Fund Katrina Relief Fund Betty Smith Burn Fund Little Betty Benefit Fund

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Benefit, Tragedy or Memorial Account

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance: $250,000 per organization.

8. Miscellaneous: a. Some small organizations will not have outside documents. You will have to identify all signatories if your bank decides to open these accounts.

b. Do not set up as a personal account unless the SSN or the person on the account is signing. And the checks are coming in made out personally to that person.

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CHECKLIST FOR BENEFIT, TRAGEDY OR MEMORIAL ACCOUNTS

Checklist for Benefit, Tragedy or Memorial Accounts

___ Required information on nonprofit association

___ Valid identification

___ Charter, Bylaws (if available)

___ Minutes (if available)

___ Report to IRS in EIN of Association

___ Account Styling: Little Johnny Hospital Fund Katrina Relief Fund Betty Smith Burn Fund Little Betty Benefit Fund

___ Account Ownership: Nonprofit

___ Nondocumentary verification

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Government lists

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CAMPAIGN ACCOUNTS

1. Description

Campaign accounts are accounts designated for individuals to run for office. 2. Insurance

Nonprofit organizations are separately insured for $250,000.

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TABLE: CAMPAIGN ACCOUNTS

Campaign Accounts

1. Required Information: (Before opening account)

Name Address Taxpayer identification— the account will

use the employer identification number of organization.

2. IRS Reporting: Report in EIN of campaign

3. Documentary Requirements: (Reasonable time after opening)

Valid identification on all persons opening the account

My bank does/does not require all signers to complete CIP. Government Certified Document

(requirements vary from state to state): Political action committees which anticipate either receiving contributions or making expenditures during the calendar year – file with government entity

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

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Campaign Accounts

4. Suggested nondocumentary verification: (Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by

account officer Third party verification Previous financial institution

references

5. Account Styling: Name of organization Examples: Friends of Sam Brownback

Campaign Campaign Fund for Senator

Hutchison Joe Biden Campaign Fund

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance: $250,000 per organization.

8. Miscellaneous: Some small organizations will not have outside documents. You will have to identify all signatories if your bank decides to open these accounts.

PACs (Political Action Committees) will be organized for a purpose and usually have a state registration.

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CHECKLIST FOR CAMPAIGN ACCOUNTS

Checklist for Campaign Accounts

___ Required information on campaign

___ Valid identification on all signatories

___ Report to IRS in EIN of Campaign

___ Statement of Organization (if receiving contributions or making expenditures in excess of $1000)

___ Account Styling: Friends of Sam Brownback Campaign

Campaign Fund for Senator Hutchison

Joe Biden Campaign Fund

___ Account Ownership: Nonprofit

___ Nondocumentary verification

___ Bank Provided Resolution

___ Bank Provided Signature Card

___ Government lists

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LAW: CAMPAIGN FINANCE

See your state’s statutes regarding campaign accounts. [Note: the location of your state’s statutes can be found on our website https://gettechnicalinc.com/resources/state-specific-resources]

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POLITICAL ACTION COMMITTEE

1. Description

Source Wikipedia

In the United States, a political action committee (PAC) is a type of organization that pools campaign contributions from members and donates those funds to campaign for or against candidates, ballot initiatives, or legislation.[1][2] The legal term PAC has been created in pursuit of campaign finance reform in the United States. This term is quite specific to all activities of campaign finance in the United States. Democracies of other countries use different terms for the units of campaign spending or spending on political competition (see political finance). At the U.S. federal level, an organization becomes a PAC when it receives or spends more than $2,600 for the purpose of influencing a federal election, according to the Federal Election Campaign Act.[3] At the state level, an organization becomes a PAC according to the state's election laws.

• Contributions from corporate or labor union treasuries are illegal, though they may sponsor a PAC and provide financial support for its administration and fundraising;

• Union-affiliated PACs may only solicit contributions from members; • Independent PACs may solicit contributions from the general public and must pay their

own costs from those funds.

Federal multi-candidate PACs may contribute to candidates as follows:

• $5,000 to a candidate or candidate committee for each election (primary and general elections count as separate elections);

• $15,000 to a political party per year; and • $5,000 to another PAC per year. • PACs may make unlimited expenditures independently of a candidate or political party

In its 2010 case Citizens United v. Federal Election Commission, the United States Supreme Court overturned sections of the Campaign Reform Act of 2002 (also known as the McCain-Feingold Act) that had prohibited corporate and union political independent expenditures in political campaigns.[4] Citizens United made it legal for corporations and unions to spend from their general treasuries to finance independent expenditures related to campaigns, but did not alter the prohibition on direct corporate or union contributions to federal campaigns.[5][6] Organizations seeking to contribute directly to federal candidate campaigns must still rely on traditional PACs for that purpose.[7]

Federal law formally allows for two types of PACs: connected and non-connected. Judicial decisions added a third classification, independent-expenditure only committees, which are colloquially known as "Super PACs".

Connected PACs

Most of the 4,600 active, registered PACs are "connected PACs" established by businesses, labor unions, trade groups, or health organizations. These PACs receive and raise money from a "restricted class", generally consisting of managers and shareholders in the case of a corporation and members in the case of a union or other interest group. As of January 2009, there were 1,598 registered corporate PACs, 272 related to labor unions and 995 to trade organizations.[8]

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Non-connected PACs

Groups with an ideological mission, single-issue groups, and members of Congress and other political leaders may form "non-connected PACs". These organizations may accept funds from any individual, connected PAC, or organization. As of January 2009, there were 1,594 non-connected PACs, the fastest-growing category.[8]

Leadership PACs

Elected officials and political parties cannot give more than the federal limit directly to candidates. However, they can set up a Leadership PAC that makes independent expenditures. Provided the expenditure is not coordinated with the other candidate, this type of spending is not limited.[9]

Under the FEC rules, leadership PACs are non-connected PACs, and can accept donations from individuals and other PACs. Since current officeholders have an easier time attracting contributions, Leadership PACs are a way dominant parties can capture seats from other parties. A leadership PAC sponsored by an elected official cannot use funds to support that official's own campaign. However, it may fund travel, administrative expenses, consultants, polling, and other non-campaign expenses.

Between 2008 and 2009, leadership PACs raised and spent more than $47 million.[13]

Controversial use of leadership PACs

• Former Rep. John Doolittle's (R) leadership PAC paid 15% to a firm that only employed his wife. Payouts to his wife's firm were $68,630 in 2003 and 2004, and $224,000 in 2005 and 2006. The Doolittle home was raided in 2007.[14] After years of investigation, the Justice Department dropped the case with no charges in June 2010.

• One Leadership PAC purchased $2,139 in gifts from Bose Corporation.[15] • Former Rep. Richard Pombo (R) used his leadership PAC to pay hotel bills ($22,896) and

buy baseball tickets ($320) for donors.[16] • Former Speaker Nancy Pelosi's (D) leadership PAC, Team Majority, was fined $21,000

by federal election officials "for improperly accepting donations over federal limits."[17]

Super PACs

Super PACs, officially known as "independent-expenditure only committees," may not make contributions to candidate campaigns or parties, but may engage in unlimited political spending independently of the campaigns. Unlike traditional PACs, they can raise funds from individuals, corporations, unions, and other groups without any legal limit on donation size.[18]

Super PACs were made possible by two judicial decisions: the aforementioned Citizens United v. Federal Election Commission and, two months later, Speechnow.org v. FEC. In Speechnow.org, the federal Court of Appeals for the D.C. Circuit held that PACs that did not make contributions to candidates, parties, or other PACs could accept unlimited contributions from individuals, unions, and corporations (both for profit and not-for-profit) for the purpose of making independent expenditures.

The result of the Citizens United and SpeechNow.org decisions was the rise of a new type of political action committee in 2010, popularly dubbed the "super PAC".[19] In an open meeting on July 22, 2010, the FEC approved two Advisory Opinions to modify FEC policy in accordance with the legal decisions.[20] These Advisory Opinions were issued in response to requests from two existing PACs, Club for Growth, and Commonsense Ten, which later became Senate Majority PAC. The opinions gave a sample wording letter which all Super PACs must submit to qualify for the deregulated status, and such letters continue to be used by Super PACs up to the present date. FEC Chairman Steven T. Walther dissented on both opinions and issued a statement giving his thoughts. In the statement,

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Walther stated "There are provisions of the Act and Commission regulations not addressed by the court in SpeechNow that continue to prohibit Commonsense Ten from soliciting or accepting contributions from political committees in excess of $5,000 annually or any contributions from corporations or labor organizations." (emphasis in original)[21]

The term "Super PAC," was coined by reporter Eliza Newlin Carney.[22] According to Politico, Carney, a staff writer covering lobbying and influence for CQ Roll Call, "made the first identifiable, published reference to 'super PAC' as it’s known today while working at National Journal, writing on June 26, 2010, of a group called Workers’ Voices, that it was a kind of '"super PAC" that could become increasingly popular in the post-Citizens United world.'"[23]

According to FEC advisories, Super PACs are not allowed to coordinate directly with candidates or political parties. This restriction is intended to prevent them from operating campaigns that complement or parallel those of the candidates they support or engaging in negotiations that could result in quid pro quo bargaining between donors to the PAC and the candidate or officeholder. However, it is legal for candidates and Super PAC managers to discuss campaign strategy and tactics through the media.[24][25]

2012 Election

Super PACs may support particular candidacies. In the 2012 presidential election, Super PACs played a major role, spending more than the candidates' election campaigns in the Republican primaries.[26] As of early April 2012, Restore Our Future—a Super PAC usually described as having been created to help Mitt Romney's presidential campaign—had spent $40 million. Winning Our Future (a pro–Newt Gingrich group) spent $16 million.[27] Some Super PACs are run or advised by a candidate's former staff or associates.[28]

In the 2012 election campaign, most of the money given to super PACs came from wealthy individuals, not corporations.[26] According to data from the Center for Responsive Politics, the top 100 individual super PAC donors in 2011–2012 made up just 3.7% of contributors, but accounted for more than 80% of the total money raised,[29] while less than 0.5% of the money given to “the most active Super PACs” was donated by publicly traded corporations.[30] Super PACs have been criticized for relying heavily on negative ads.[31]

As of February 2012, according to Center for Responsive Politics, 313 groups organized as Super PACs had received $98,650,993 and spent $46,191,479. This means early in the 2012 election cycle, PACs had already greatly exceeded total receipts of 2008. The leading Super PAC on its own raised more money than the combined total spent by the top 9 PACS in the 2008 cycle.[32]

The 2012 figures do not include funds raised by state level PACs.

Disclosure rules

By January 2010, at least 38 states and the federal government required disclosure for all or some independent expenditures or electioneering communications.[33] These disclosures were intended to deter potentially or seemingly corrupting donations.[34][35]

Yet despite disclosure rules, it is possible to spend money without voters knowing the identities of donors before the election.[36] In federal elections, for example, political action committees have the option to choose to file reports on a "monthly" or "quarterly" basis

.[37][38][39] This allows funds raised by PACs in the final days of the election to be spent and votes cast before the report is due.

In one high-profile case, a donor to a super PAC kept his name hidden by using an LLC formed for the

purpose of hiding their personal name.[40] One super PAC, that originally listed a $250,000 donation from an LLC that no one could find, led to a subsequent filing where the previously "secret donors" were revealed.[41] However, campaign finance experts have

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argued that this tactic is already illegal, since it would constitute a contribution in the name of another.[42]

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PUBLIC FUND ACCOUNTS

1. Description

A business account set up for a public or governmental unit. If incorporated, see “Corporations” for documentation and set up. If not incorporated there is no standard document authorizing the opening of an account, it usually consists of a letter from the public unit.

2. Insurance

Public funds are insured for each unit of government up to $250,000. There are special rules governing public funds, please call the FDIC with particular concerns.

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TABLE: PUBLIC FUNDS

Public Funds

1. Required Information on Public Fund:

(Before opening account)

Name Address Taxpayer identification— the account will use

the employer identification number of the public fund.

2. IRS Reporting: Report in EIN of Public Fund

3. Documentary Requirements: (Reasonable time after opening)

Valid Identification on person opening the account

Authorization—you will need some authorization provided by the public fund for the person to sign.

Bank Provided Resolution—there is no bank provided resolution.

Bank Provided Signature Card—Bank provided signature contract and agreement. Only change and add signers with proper authority from the public fund.

4. Suggested nondocumentary verification:

(Reasonable time after opening)

A CIP program must also have nondocumentary verification. Suggestions include: Welcome letter Call to customer to thank for business Delivery of checks to location by account

officer Third party verification Previous financial institution references

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Public Funds

5. Account Styling: Name of government unit

6. Consult Government Lists: Section 326 List OFAC List

7. Insurance: Public units are insured for $250,000 for each unit. See special rules under FDIC insurance governing public funds.

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THESE AREAS MUST BE ADDRESSED IN YOUR POLICY

Introduction Overall goals of AML program Risk Assessment BSA Compliance Officer/OFAC Officer in that section Training Independent Testing Internal Controls to ensure ongoing compliance Recognition of Fines and Penalties

Core Sections if they apply to you: Customer Identification Program Customer Due Diligence Suspicious Activity Reporting Currency Transaction Reporting Purchase and Sale of Monetary Instruments Recordkeeping Fund Transfers Recordkeeping Foreign Correspondent Account Recordkeeping and Due Diligence Private Banking Due Diligence Program (Non US Persons) International Transportation of Currency or Monetary Instrument Reporting OFAC Possible Record Retention Enforcement Guidance Red Flags for Money Laundering Products and Services if they apply to you: Correspondent Accounts (Domestic) Correspondent Accounts (Foreign) Bulk Shipments of Currency U. S. Dollar Drafts Payable through Accounts Pouch Activities Electronic Banking Funds Transfers Automated Clearing House Transactions Electronic Cash Third-Party Payment Processors

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Purchase and Sale of Monetary Instruments Brokered Deposits Privately Owned Automated Teller Machines Nondeposit Investment Products Insurance Concentration Accounts Lending Activities Trade Finance Activities Private Banking Trust and Asset Management Services Persons and Entities if they apply to you: Nonresident Aliens and Foreign Individuals Politically Exposed Person Embassy and Foreign consulate Accounts Nonbank financial Institutions Professional Service Providers Nongovernmental Organizations and Charities Business Entities Cash Intensive Businesses

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Summary Of Deposit Accounts

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Type of Account

Account Styling and Ownership

CIP Required Information on person or entity opening account

Documentary Verification

Nondocumentary Verification Suggestions

Government Lists

Nonprofit Corporations Boy Scouts of America, Inc. Name Address Date of birth EIN on Corporation

Valid identification on corporate secretary. This is a recommendation some banks require the CIP on all signers.

My financial institution does/does not require all signers to Complete CIP.

Government Issued Paperwork: Most states either have a certificate of incorporation or application stamped “filed” after approval.

IRS 501(c) Tax determination letter Minutes from Board Meeting: The customer should provide an excerpt from the minutes of the last board meeting where officers were elected—specifically the Secretary of the corporation since this person must sign the resolution. Sometimes the minutes are built into the bank’s resolution.

Bank Provided Resolution: Provided by the bank for corporations signed by the secretary of the business. There may be other signers on the account. These signers may be changed at any time, provided the corporation provides new minutes, new resolution and new signature card.

Bank Provided Signature Card: Provided by the bank signed by those authorized in the resolution. It is the contract between the bank and the customer.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Contact Secretary of State’s Office

Section 326 List OFAC

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Type of Account

Account Styling and Ownership

CIP Required Information on person or entity opening account

Documentary Verification

Nondocumentary Verification Suggestions

Government Lists

Formal Nonprofit and Unincorporated Associations

Rotary Kiwanis Lions Club

Name Address Date of birth EIN

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

My bank does/does not require CIP on all signers.

Charter, By-laws or Letter of Purpose: Provided by customer.

Minutes of Meeting: Provided by customer authorizing account opening and signatories..

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Third Party Verification Previous financial institution References

Section 326 List OFAC

Informal Nonprofit or Unincorporated Associations

Austin Little League Flower Fund Livingston Hunting Club 1975 Class Reunion

Name Address EIN

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Third Party Verification Previous financial institution References

Section 326 List OFAC

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Type of Account

Account Styling and Ownership

CIP Required Information on person or entity opening account

Documentary Verification

Nondocumentary Verification Suggestions

Government Lists

Benefit, Tragedy or Memorial Account

Little Johnny Hospital Fund Katrina Relief Fund Betty Smith Burn Fund Little Betty Benefit Fund

Name Address EIN

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Third Party Verification Previous financial institution References

Section 326 List OFAC

Homeowners’ Association River Ranch Aspen Highlands Homeowners’

Association

Name Address EIN

Valid identification: On person opening the account. Sometimes banks require identification on all signatories.

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Third Party Verification Previous financial institution References

Section 326 List OFAC

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Type of Account

Account Styling and Ownership

CIP Required Information on person or entity opening account

Documentary Verification

Nondocumentary Verification Suggestions

Government Lists

Campaign Accounts Friends of Sam Brownback Campaign

Campaign Fund for Senator Hutchison

Joe Biden Campaign Fund

Name Address EIN

Valid identification on all persons opening the account

My bank does/does not require all signers to complete CIP.

Government Certified Document (requirements vary from state to state): Political action committees which anticipate either receiving contributions or making expenditures during the calendar year – file with government entity

Bank Provided Resolution: Resolution authorizing the account and who will sign.

Bank Provided Signature Card: Contract between bank and customer.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Third Party Verification Previous financial institution References

Section 326 List OFAC

Public Fund Name of Government Unit Name Address EIN of Public Fund

Valid Identification on person opening the account

Authorization—You will need some authorization provided by the public fund for the person to sign.

Bank Provided Resolution—There is no bank provided resolution.

Bank Provided Signature Card—Bank provided signature contract and agreement. Only change and add signers with proper authority from the public fund.

Telecheck or Check Systems Credit Report Letter of Welcome Phone call verification Delivery of checks Third Party Verification Previous financial institution References

Section 326 List OFAC

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Appendix

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FDIC: UNINCORPORATED ASSOCIATIONS

Definitions This ownership category includes all deposit accounts owned by a corporation, partnership or unincorporated association.

• A corporation is defined as an organization that is incorporated under the laws of the state in which it is located. This definition includes both for-profit and not-for-profit corporations, as well as "Subchapter S," "Limited Liability (LLC)" and professional (PC) corporations.

• A partnership is defined as an association of two or more persons or entities formed to carry on, as co-owners, an unincorporated business for profit.

• An unincorporated association is defined as an association of two or more persons formed for some religious, educational, charitable, social or other non-commercial purpose.

Important! Accounts of a sole proprietorship are not covered under this account category. Sole proprietorship accounts are insured as the single accounts of the owner.

Insurance Limit The deposit accounts of a corporation, partnership or unincorporated association are insured up to $250,000 provided the corporation, partnership or unincorporated association is engaged in an "independent activity."

The term independent activity means that the entity is operated primarily for some purpose other than to increase deposit insurance coverage. If a corporation, partnership or unincorporated association is not engaged in an independent activity, for insurance purposes the FDIC will consider its deposits to be owned by the person or persons who established the account.

Corporations and partnerships must be valid under state law to receive insurance coverage that is separate from any insurance coverage that the owners, officers or partners of the business might otherwise receive.

Deposits held in the name of a corporation, partnership or unincorporated association is insured separately from the personal deposits of the owner(s) or officials of the organization.

Example: The president of a corporation has a personal multiple-party account with her husband at the same bank where the corporation's funds are deposited. The president is an authorized signatory on the corporate account. The multiple-party account with her husband is

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insured up to $500,000 and the corporation's deposits are separately insured up to $250,000.

Unincorporated Associations Deposit accounts held in the name of an unincorporated association engaged in an independent activity are insured as the association's funds, separately from the personal deposits of the members.

Important! Insurance coverage for deposits held by an unincorporated association is a maximum of $250,000, regardless of the number of signatories on the account or the number of members that the association may have. The number of signatories on the association's accounts, or the number of members of the association, does not affect insurance coverage. Example: Good Fences Homeowners Association, which has 150 members, maintains two different deposit accounts at the same bank: a checking account for its operating expenses and a reserve account for improvements to the common areas. Both of these accounts are added together and insured as the deposits of the homeowners association, up to $250,000. It does not matter for deposit insurance purposes that the accounts are designated for different purposes or the association has 150 members.

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OFFICE OF FOREIGN ASSETS CONTROL – FREQUENTLY ASKED QUESTIONS

Office of Foreign Assets Control Questions from Financial Institutions: Through corporate giving programs, many banks contribute toward charities and other nonprofits. To what extent does a bank need to review the recipients of these gifts or the principals of the charities?

Donations to charitable institutions must be handled as any other financial transaction. The donating bank or institution should crosscheck the recipient names against OFAC's SDN list and assure that the donations are in compliance with OFAC sanctions programs. [09-10-02]

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IRS WEB SITE AND EINS

http://www.irs.gov/businesses/small/article/0,,id=102767,00.html

Online EIN: Form SS-4 Instructions

Section references are to the Internal Revenue Code unless otherwise noted.

Purpose of Form

Use Form SS-4 to apply for an Employer Identification Number (EIN). An EIN is a nine-digit number (for example, 12-3456789) assigned to sole proprietors, corporations, partnerships, estates, trusts, and other entities for tax filing and reporting purposes. The information you provide on this form will establish your business tax account.

These instructions are not all-inclusive. Complete instructions can be found in Instructions for Form SS-4 (PDF). Information pertaining to entities not permitted to complete an online application has been removed. Specific instructions have been provided for various line item entries to agree with space and character limitations of the online program.

We want to ensure your application is not rejected or delayed due to incomplete or inaccurate information being submitted. Refer to Top 5 Reasons for Rejection of an Application .

Who Cannot File Online (Submit your application by phone, fax, or mail as shown on "Where to File Your Taxes" (for Form SS-4).)

• Individuals who do not have a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)

• Foreign entities located outside the 50 United States (including Puerto Rico, Virgin Islands, American Samoa and Guam)

• Entities that are incorporated in a foreign location but are using a domestic mailing address

• REMICs • Federal, state, or local governments • Indian Tribal Governments

In addition, Third Party Designees submitting a Form 2848, Power of Attorney and Declaration of Representative, or Form 8821, Taxpayer Information Authorization should use our phone, fax, or mail options as shown on "Where to File Your Taxes" (for Form SS-4). You must submit a copy of the form authorizing you to receive mail on behalf of the applicant.

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The online application generally cannot accurately identify an employer agent appointed by a Form 2678, Employer Appointment of Agent Under Section 3504, Internal Revenue Code. Employer agents: please use our phone, fax, or mail options as shown on "Where to File Your Taxes" (for Form SS-4) to ensure your EIN is correctly assigned.

After accessing the online SS-4 application, do not press the "Back" button to return to instructions or other Web pages. Doing so will result in a loss of all information entered and will require you to input the information again. We suggest you print the instructions for easy reference prior to completing your online Form SS-4 application.

Caution: An EIN is for use in connection with your business activities only. Do NOT use your EIN in place of your Social Security Number (SSN).

Who Must File

You must file this form if you have not been assigned an EIN before, and one or more of the following applies to your situation:

• You pay wages to one or more employees, including household employees. • You are required to have an EIN to use on any return, statement, or other document, even

if you are not an employer. • You are a withholding agent required to withhold taxes on income, other than wages,

paid to a nonresident alien (individual, corporation, partnership, etc.). A withholding agent may be an agent, broker, fiduciary, manager, tenant, or spouse, and is required to file Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons.

• You file Schedule C, Profit or Loss From Business, Schedule C-EZ, Net Profit From Business, or Schedule F, Profit or Loss From Farming, or Form 1040, U.S. Individual Income Tax Return, and have a Keogh plan or are required to file excise; employment; or alcohol, tobacco, or firearms returns.

The following entities must use EINs, even if they do not have any employees:

• Trusts, except for the following:

1. Certain grantor-owned revocable trusts (e.g. Living Trust). (Refer to the Instructions for Form 1041, U.S. Income Tax Return for Estates and Trusts.)

Individual retirement arrangement (IRA) trusts, unless the trust has to file Form 990-T, Exempt Organization Business Income Tax Return. (Refer to the Instructions for Form 990-T.)

• Estates • Partnerships • Corporations • Nonprofit organizations (churches, clubs, etc.) • Farmers' cooperatives

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• Plan administrators (A plan administrator is the person or group of persons specified as the administrator by the instrument under which the plan is operated.)

About the Electronic Federal Tax Payment System (EFTPS)

EFTPS is a service provided free by the U.S. Department of the Treasury that enables businesses and individuals to make their federal tax payments electronically, 24 hours a day, 7 days a week.

Based on the information you submit on your application or if you indicate you will have employees, you will automatically be enrolled in EFTPS so you can make all your deposits online or by phone. Within a few days you will receive instructions by mail for activating your EFTPS enrollment. You will also receive an EFTPS Personal Identification Number (PIN) that you will use to make your payments, as well as instructions for obtaining an Internet Password you will need if you wish to make your payments online. No action is required at this time.

Instructions for Third Parties Filing Forms SS-4 for Other Applicants

The Code requires that the person required to furnish an EIN apply for one. If it is not the applicant who is making an online application, the applicant must authorize the third party to apply for and receive the EIN. The following procedures must be used by third parties to get authorization from the applicant to submit the Form SS-4 on behalf of the applicant and receive an EIN:

• The applicant (not the third party) must sign a completed Form SS-4, including the Third Party Designation, prior to the third party making the online application.

• The applicant must read and sign a statement that he or she understands, by providing his or her Social Security Number to the third party, that he or she is authorizing the third party to apply for and receive the EIN on his or her behalf and to answer questions about the completion of the Form. There is no published form for this purpose, so the third party can print out this web page and have the applicant sign, or the third party can use their own printed form for this statement.

• The third party must retain on file the signed completed Form SS-4, as well as the applicant's statement authorizing the online filing.

The third party designee’s address cannot be used as the mailing address on lines 4a and 4b, or the location address on lines 5a and 5b of Form SS-4 when applying online unless the third party has a valid Form 2848, Power of Attorney and Declaration of Representative, or Form 8821, Tax Information Authorization. If you wish to use a third party’s address and have a valid Form 2848 or Form 8821, please submit Form SS-4 using our phone, fax, or mail options as shown on "Where to File Your Taxes" (for Form SS-4).

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When to Apply for a New EIN

New Business If you become the new owner of an existing business, do not use the EIN of the former owner. If you already have an EIN, use that number. If you do not have an EIN, apply for one on this form. If you become the "owner" of a corporation by acquiring its stock, use the corporation's existing EIN.

Changes in Organization or Ownership If you already have an EIN, you may need to get a new one if either the organization or ownership of your business changes. If you incorporate a sole proprietorship or form a partnership, you must get a new EIN. However, do not apply for a new EIN if:

• You change only the name of your business, or • You elected on Form 8832, Entity Classification Election, to change the way the entity is

taxed.

Note: If you are electing to be an "S corporation," be sure you file Form 2553, Election by a Small Business Corporation.

File only one Form SS-4, regardless of the number of businesses operated or trade names under which a business operates. However, each corporation in an affiliated group must file a separate application.

Specific Instructions

The instructions that follow are for those items that are not self-explanatory. A complete set of instructions for completing Form SS-4 can be found in Instructions for Form SS-4 (PDF).

• If an entry is not a required field and does not apply to you, leave that field blank. • Do not use any characters other than alpha letters, numeric digits, hyphen (-), ampersand

(&) or spaces when completing the online application.

Line 1. Enter the legal name of the entity applying for the EIN exactly as it appears on the social security card, charter, or other applicable legal document.

• Corporations - include your corporate suffix (i.e., Inc, Co, etc.) • Limited Liability Companies - include “LLC,” “PLC,” or other identifying suffix on line

1.

Individual. Enter your first name, middle initial and last name. If you are a sole proprietor, enter your individual name, not your business name. Enter your business name on line 2. Do not use abbreviations or nicknames on line 1.

Trusts. Enter the exact name of the trust as it appears on the trust instrument.

Estate of a decedent. Enter the name of the estate.

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Partnerships. Enter the legal name of the partnership as it appears in the partnership agreement. Do not list the names of the partners on line 1. Refer to the specific instructions for line 7 found in Instructions for Form SS-4 (PDF).

Corporations. Enter the corporate name as it appears in the corporation charter or other legal document creating it.

Plan administrators. Enter the name of the plan administrator. A plan administrator who already has an EIN should use that number.

Line 2. Enter the trade name of the business if different from the legal name. The trade name is the "doing business as" name. A trade name must never include the corporate suffix; e.g., Co. or Inc.

Note: Use the full legal name on line 1 on all tax returns filed for the entity. However, if you enter a trade name on line 2, and choose to use the trade name instead of the legal name, enter the trade name on all returns you file. To prevent processing delays and errors, always use either the legal name only or the trade name only on all tax returns.

Line 3.

• Trusts enter the name of the trustee. Estates enter the name of the executor, administrator, or other fiduciary.

• If the entity type applying has a designated person to receive tax information, enter that person's name as the "care of" person. Enter the first name, middle initial and last name.

Lines 4a-b (Mailing address). Enter the mailing address for the entity's correspondence. (This must not be the Designated Third Party’s address.) If line 3 is completed, enter the address for the executor, trustee or care of person. Generally, this address will be used on all tax returns.

File Form 8822, Change of Address, to report any subsequent changes to the entity's mailing address.

Lines 5a-b (Street address). Provide the entity's physical address only if different from its mailing address shown in lines 4a-b. Do not enter a P.O. box number here.

Line 6. County and state where principal business is located. Enter the entity's primary physical location.

Line 7. Enter the first name, middle initial, last name, and SSN of a principal officer if the business is a corporation; of a general partner if a partnership; of the owner of a single member entity that is disregarded as an entity separate from its owner; or of a grantor, owner, or trustor if a trust. If the person in question is an alien individual with a previously assigned individual taxpayer identification number (ITIN), enter the ITIN in the space provided, instead of an SSN. Do not include any title such as partner, general partner, or trustor. This will cause the online program to reject your application after it is transmitted.

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Line 8a. Select the choice that best describes the type of entity applying for the EIN. If you are an alien individual with an ITIN previously assigned to you, enter the ITIN in place of a requested SSN. In all cases, an entry must be made on line 8a to successfully process your application. Do not check the box labeled “Other” unless none of the other types of entities are applicable (i.e., Sole Proprietor, Trust, Estate, Corporation, etc.) or you are instructed to do so in the specific instructions below.

Caution: This is not an election for a tax classification of an entity.

If you are a limited liability company (LLC) please carefully read the following information:

A limited liability company (LLC) is an entity organized under the laws of a state or foreign country as a limited liability company. For Federal tax purposes, an LLC may be treated as a partnership or corporation or be disregarded as an entity separate from its owner.

By default, a domestic LLC with only one member is disregarded as an entity separate from its owner and must include all of its income and expenses on the owner’s tax return (e.g. Schedule C (Form 1040)). Also by default, a domestic LLC with two or more members is treated as a partnership. A domestic LLC may file Form 8832or Form 2553to avoid either default classification and elect to be classified as an association taxable as a corporation or S Corporation

• A single-member, domestic LLC that accepts the default classification (above) and wants an EIN for filing employment tax returns (see above) or non-Federal purposes, such as a state requirement, must check the “Other” box and write “Disregarded Entity.”

• A single-member, domestic LLC that accepts the default classification (above) and does not have employees, does not need an EIN and generally should not file Form SS-4. Generally the LLC should use the name and EIN of its owner for all Federal tax purposes.

Note: The reporting and payment of employment taxes for employees of the LLC may be made using the name and EIN of either the owner or the LLC as explained in Notice 99-6. You can find Notice 99-6 on page 12 of Internal Revenue Bulletin 1999-3. Also, if the LLC applicant indicates in box 13 that it has employees or expects to have employees, the owner (whether an individual or other entity) of a single-member domestic LLC will also be assigned its own EIN (if it does not already have one) even if the LLC will be filing the employment tax returns).

• A multi-member, domestic LLC that accepts the default classification (above) must check the “Partnership” box. Include “LLC” or other identifying prefix in the company name on line 1.

• A domestic LLC that will be filing Form 8832or Form 2553 to elect corporate status must check the “Corporation” box and write in “Single Member” or “Multi Member” next to the box. Include “LLC” or other identifying prefix in the company name on line 1.

Note: All multi-member LLCs are established as partnerships. When you receive the IRS letter verifying your EIN assignment, it will show a filing requirement for Form1065, U.S. Return of

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Partnership Income. The filing requirement will be changed when your Form 8832 or Form 2553 is received and accepted by the service. Form 1120 or 1120S cannot be filed until you have received notification from the service that your Form 8832 or Form 2553 has been approved.

Sole proprietor. Select this entity type if you file Schedules C, C-EZ, or F (Form 1040) and have a qualified plan, or are required to file excise, employment, or alcohol, tobacco, or firearms returns, or are a payer of gambling winnings. Enter your SSN (or ITIN) in the space provided. The name on line 1 and SSN/ITIN must match Social Security Administration/IRS records.

Corporation. This box is for any corporation other than a personal service corporation. If you check this box, enter the income tax form number to be filed by the entity in the space provided (1120, 1120S, etc.).

Note: If you entered “1120S” after the “Corporation” checkbox, the corporation must file Form 2553 no later than the 15th day of the 3rd month of the tax year the election is to take effect. When you receive the IRS letter verifying your EIN assignment, it will show a Form 1120 filing requirement. Once Form 2553 is received, processed, and approved, the filing requirement will be updated.

Personal service corporation. Select this choice if the entity is a personal service corporation. An entity is a personal service corporation for a tax year only if:

• The principal activity of the entity during the testing period (prior tax year) for the tax year is the performance of personal services substantially by employee-owners, and

• The employee-owners own at least 10% of the fair market value of the outstanding stock in the entity on the last day of the testing period.

Personal services include performance of services in such fields as health, law, accounting, or consulting. For more information about personal service corporations, refer to the Instructions for Forms 1120 and 1120-A, and Pub. 542, Corporations.

Other corporation. This choice is for any corporation other than a personal service corporation.

Household employer. Please review the following selections and follow the instructions for the one that matches your entity type.

• If you are an individual, check the box for “Sole proprietor” and enter your SSN in the line next to the box. On line 13, notate your total number of household employees in the appropriate box. On line 14, check the “other” box and notate “household employer.” This will allow us to capture the necessary information identifying you as a household employer.

• If you are a trust or estate that qualifies as a household employer, you do not need a separate EIN for reporting tax information relating to household employees; use the EIN of the trust or estate.

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Note: If you are a state or local agency serving as a tax reporting agent for public assistance recipients who become household employers, please submit your application by phone, fax, or mail as shown on "Where to File Your Taxes" (for Form SS-4).

Line 9. You must select one choice only. An explanation of all reasons for applying can be found in Instructions for Form SS-4 (PDF). Note: There are 20 spaces in each descriptive field.

Started new business. Select this choice if you are starting a new business that requires an EIN. If you select this reason, enter the type of business being started.

Note: Do not apply if you already have an EIN and are only adding another place of business.

Hired employees. Select this choice if the existing business is requesting an EIN because it has hired or is hiring employees, and is therefore required to file employment tax returns. Do not apply if you already have an EIN and are only hiring employees. For information on the applicable employment taxes for family members, refer to Circular E, Employer's Tax Guide (Publication 15).

Created a pension plan. Select this choice if you have created a pension plan and need this number for reporting purposes. Also, enter the type of plan.

Note: Select this choice if you are applying for a trust EIN when a new pension plan is established.

Changed type of organization. Select this choice if the business is changing its type of organization. For example, if the business was a sole proprietorship and has been incorporated or has become a partnership. If you select this choice, specify in the space provided the type of change made, for example, "from sole proprietorship to partnership."

Purchased existing business. Select this choice if you purchased an existing business. Do not use the former owner's EIN. Do not apply for a new EIN if you already have one. Use your own EIN.

Created a trust. Select this choice if you created a trust, and enter the type of trust created. For example, indicate if the trust is a nonexempt charitable trust or a split-interest trust.

Note: Do not select this choice if you are applying for a trust EIN when a new pension plan is established. Select "Created a pension plan."

Exception: Do not file this form for certain grantor-type trusts. The trustee does not need an EIN for the trust if the trustee furnishes the name and TIN of the grantor/owner and the address of the trust to all payors. Refer to the Instructions for Form 1041 for more information.

Other (specify). Select this choice if you are requesting an EIN for any other reason, and enter the reason.

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Line 10. If you are starting a new business, enter the starting date of the business. If the business you acquired is already operating, enter the date you acquired the business. Trusts should enter the date the trust was legally created. Estates should enter the date of death of the decedent whose name appears on line 1 or the date when the estate was legally funded, whichever is later.

Line 11. Enter the last month of your accounting year or tax year. An accounting or tax year is usually 12 consecutive months, either a calendar year or a fiscal year (including a period of 52 or 53 weeks). A calendar year is 12 consecutive months ending on December 31. A fiscal year is either 12 consecutive months ending on the last day of any month other than December, or a 52-53 week year. For more information on accounting periods, refer to Pub. 538, Accounting Periods and Methods.

Individuals. Your tax year generally will be a calendar year.

Partnerships. Partnerships generally must adopt one of the following tax years:

• The tax year of the majority of its partners, • The tax year common to all of its principal partners, • The tax year that results in the least aggregate deferral of income, or • In certain cases, some other tax year.

Refer to the Instructions for Form 1065, U.S. Partnership Return of Income, for more information.

Personal service corporations. A personal service corporation generally must adopt a calendar year unless:

• It can establish a business purpose for having a different tax year, or • It elects under section 444 to have a tax year other than a calendar year.

Trusts. Generally, a trust must adopt a calendar year except for the following:

• Tax-exempt trusts, • Charitable trusts, and • Grantor-owned trusts.

Line 12. If the business has, or will have employees, enter the date on which the business began or will begin to pay wages. If the business does not plan to have employees, leave blank.

Withholding agent. Enter the date you began, or will begin, to pay income to a nonresident alien. This also applies to individuals who are required to file Form 1042 to report alimony paid to a nonresident alien.

Line 13. For a definition of agricultural labor (farm work), refer to Circular A, Agricultural Employer's Tax Guide (Publication 51). For a definition of household employees, refer to

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Publication 926. Household employees may only be indicated by Sole Proprietors, trusts and estates.

Line 14. Generally, enter the exact type of business being operated (for example, advertising agency, farm, food or beverage establishment, labor union, real estate agency, steam laundry, rental of coin-operated vending machine, or investment club). Also state if the business will involve the sale or distribution of alcoholic beverages.

Nonprofit organization (other than governmental). Enter whether organized for religious, educational, or humane purposes, and the principal activity (for example, religious organization- hospital, charitable).

Mining and quarrying. Specify the process and the principal product (for example, mining bituminous coal, contract drilling for oil, or quarrying dimension stone).

Contract construction. Specify whether general contracting or special trade contracting. Also, show the type of work normally performed (for example, general contractor for residential buildings or electrical subcontractor).

Food or beverage establishments. Specify the type of establishment and state whether you employ workers who receive tips (for example, lounge-yes).

Trade. Specify the type of sales and the principal line of goods sold (for example, wholesale dairy products, manufacturer's representative for mining machinery, or retail hardware).

Manufacturing. Specify the type of establishment operated (for example, sawmill or vegetable cannery).

Transportation & warehousing. Check this box if the applicant provides transportation of passengers or cargo; warehousing or storage of goods, scenic or sight-seeing transportation; or support activities related to these modes of transportation.

Health care and social assistance. Check this box if the applicant is engaged in providing physical, medical, or psychiatric care using licensed health care professionals or providing social assistance activities such as youth centers, adoption agencies individual/family services, temporary shelters, etc.

Accommodation & food services. Check this box if the applicant is engaged in providing customers with lodging, meal preparation, snacks, or beverages for immediate consumption.

Wholesale-agent/broker. Check this box, if the applicant is engaged in selling goods in the wholesale market generally to other businesses for resale on their own account.

Retail. Check this box if the applicant is engaged in selling merchandise to the general public from a fixed store; by direct, mail-order, or electronic sales; or by using vending machines.

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Other. If the applicant is engaged in an activity not described above, check the "OTHER" box and specify the applicant's business activity in the space next to the box.

Line 15. If a box is checked in Line 14, on Line 15 describe the applicant's principal line of business in more detail. For example, if you checked the Construction box in line 14, enter additional detail such as "General contractor for residential buildings" in line 15.

Lines 16a-c. Check the applicable box in line 16a to indicate whether or not the entity (or individual) applying for an EIN was issued one previously. Complete lines 16b and 16c only if the Yes box in line 16a is checked. If the applicant previously applied for more than one EIN, write "See Attached" in the empty space in line 16a and attach a separate sheet providing the line 16b and 16c information for each EIN previously requested.

Third Party Designee. Complete this section only if you want to authorize the named individual to receive the entity's EIN and answer questions about the completion of Form SS-4. The designee's authority terminates at the time the EIN is assigned and released to the designee. You must complete the signature area for the authorization to be valid.

Signature. When required, the application must be signed by (a) the individual, if the applicant is an individual; (b) the president, vice president, treasurer, assistant treasurer, chief accounting officer or any other officer duly authorized so to act, if the applicant is a corporation; (c) a responsible and duly authorized member or officer having knowledge of its affairs, if the applicant is a partnership, government entity, or other unincorporated organization; or (d) the fiduciary, if the applicant is a trust or an estate.

Apply ONLINE NOW

If you have determined that you need an EIN, and are not one of the excluded entity types listed previously, then proceed with the Online EIN Application process!

If you are a third party, you must retain on file a completed copy of the SS-4 signed by the customer and the signed statement authorizing you to file the online application.

If you are not comfortable with sending information via the Internet, then download the form SS-4 PDF file and mail it to the address indicated in the instructions or follow directions on the Employer ID Numbers (EIN) - Where to Apply for an EIN page.