Quick answer, as of 2026-09-29
Before opening an account, a bank's customer identification program has to collect the customer's name, an address, and, for a U.S. person, a taxpayer identification number. An individual also provides a date of birth. For an LLC, bankers commonly add formation documents, IRS proof of an EIN, a photo ID for the signer, and the names of people who own or control the company. A domestic LLC does not file a beneficial ownership report with FinCEN in order to open the account.
Sources: 31 CFR 1020.220, the IRS single-member LLC page, the IRS EIN page, and FinCEN's BOI page. This guide is education, not legal, tax, or banking advice.
Elena and her father filed an LLC for the family bakery on a Tuesday. By Thursday she had a screenshot of the approval email and a 2 p.m. appointment. The banker asked for the operating agreement and the IRS letter that assigned the employer identification number. She had the email. She did not have either document. The account did not open that day, and the weekend's card sales went into her personal checking account again.
That sequence is common. The secretary of state can accept a formation filing while the bank is still missing papers its own rules, and in some cases federal rules, tell it to collect.
Why the appointment stalls
Customer payments, vendor checks, and payroll that land in a personal account are hard to sort later. A second appointment also means another week in which the new company has no account of its own. Owners who formed the LLC so the bakery would stay separate from the household sometimes spend the first month doing the opposite, because the folder was thin.
The first layer of that folder comes from the customer identification program in 31 CFR 1020.220. A bank required to have an anti-money laundering program must keep a written CIP as part of that program. Before the account opens, the CIP has to obtain, at a minimum:
- the customer's name
- a date of birth, if the customer is an individual
- an address
- an identification number
For a U.S. person, the identification number is a taxpayer identification number. For a customer that is not an individual, the regulation's examples are a corporation, a partnership, or a trust, and the address is a principal place of business, a local office, or another physical location. The eCFR copy of this section was current as of September 25, 2026. A federal regulator, with Treasury's concurrence, may exempt a bank or a type of account. The description here is the general rule.
The same paragraph has a narrow exception. If the customer has applied for a taxpayer identification number and has not received it, the CIP may let the bank open the account after the bank confirms the application was filed. The bank then has to obtain the number within a reasonable time. Whether a given branch will do that is the bank's procedure. The regulation does not require the branch to open the account on an "applied for" note.
When the bank verifies identity with documents, the rule gives examples. For an individual, those examples include an unexpired government-issued identification with a photograph, such as a driver's license or passport. For a customer that is not an individual, the examples are documents showing the entity exists, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument. An LLC operating agreement is not in that list. Banks still ask for one, because they want to see who is allowed to sign. That request comes from the bank, not from a sentence in 1020.220 that names operating agreements.
The CIP also includes a notice to the customer. The sample language in the regulation says federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
This article is for educational and informational purposes only and does not provide legal, tax, financial, securities, or investment advice. Business owners should consult qualified professionals before making decisions.
The documents
Name, address, and a taxpayer identification number
Put the LLC's legal name on the application the way it appears on the formation document. When you apply for an EIN, the IRS says to enter the business name as it appears on the registration or formation documents. A shortened name, a trade name that was never filed, or a missing "LLC" is enough for the banker to stop and ask for a match.
For a customer that is not an individual, 1020.220 describes the address as a principal place of business, a local office, or another physical location. A registered-agent address is where legal notices are delivered. On our Bank-Ready Pack page we say banks usually ask for the address where the business actually operates, and that many of them check it. Bring the address where the business operates.
The EIN, and proof the IRS assigned it
An employer identification number is the nine-digit tax ID the IRS assigns. You can get one free, directly from the IRS. The IRS says to register the entity with the state before you apply.
Whether the LLC is required to have one depends on how it is taxed and what it does. The IRS single-member LLC page says a domestic LLC with at least two members is classified as a partnership for federal income tax purposes unless it files Form 8832 and elects to be treated as a corporation. An LLC with one member is disregarded, and its activity goes on the owner's return, unless it files Form 8832 and elects corporate treatment. The same page says an LLC needs an EIN if it has employees or if it has to file certain excise tax forms. It also says a disregarded single-member LLC with no employees and no excise tax liability does not need an EIN, and should use the owner's name and taxpayer identification number for federal tax purposes. If that LLC needs an EIN to open a bank account, or if state tax law requires one, the IRS says the LLC can apply and obtain one.
The general EIN page says you need an EIN to operate a partnership, an LLC, or a corporation, and that if you do not need one for federal tax purposes you can still request one for banking or state tax purposes. Those two pages do not read as a single sentence. Ask a CPA which description fits your LLC before you treat either one as the whole answer. An IRS newsroom note dated August 10, 2026 says many banks require an EIN to open a business bank account.
For income-tax forms, the single-member page gives a specific example. If a disregarded LLC owned by an individual must provide a Form W-9, the W-9 should show the owner's Social Security number or EIN, not the LLC's EIN. Employment tax and certain excise taxes are handled differently, and those use the LLC's own EIN. Which number a particular bank form wants is a question for the banker and for your CPA.
Once the IRS assigns the number, the EIN page says you can use it immediately for most business needs, including opening a bank account. It also says to wait up to two weeks before the number will pass the IRS taxpayer identification number matching program, before you e-file a return, and before you make electronic tax deposits.
Banks commonly want the notice that assigned the number. The IRS lists three ways to confirm an EIN: request an entity transcript; for eligible Business Tax Account users, download a digital CP 575, which the IRS says can stand in for the original CP 575 notice series and for Letter 147C; or call the business and specialty tax line and request Letter 147C. If the number itself is lost, the IRS says an authorized person can call 800-829-4933.
Papers that show the company exists
These are the items bankers ask for at an ordinary appointment. They are not a federal list that every bank must demand in this exact form.
The formation document. States call it articles of organization, a certificate of formation, or a similar name. The CIP examples of documents that show a non-individual exists include certified articles of incorporation. A PDF from the night you filed is sometimes enough. A certified copy from the state is what many banks ask for when that PDF looks unofficial. If you only have the approval email, expect to be asked for the document itself.
A certificate of good standing, or whatever your state calls the one-page status letter. It is not one of the examples in the CIP document list. Banks and lenders still ask for it, because it shows the state still treats the company as active. Our Bank-Ready Pack page treats 30 days as the freshness window many banks apply, and notes that some accept 60. Order it close to the appointment. The longer explanation is the certificate of good standing guide, and state fees are on the certificate of good standing by state pages. A missed annual report can stop the state from issuing a clean one. That problem is covered in the cost of a missed LLC annual report.
An operating agreement, signed. Federal CIP rules do not name it. Banks ask because the agreement is where members say who may open accounts and sign. If the person at the desk is not someone the agreement authorizes, the signature card and the agreement disagree, and the application often stalls. Our pack page flags that mismatch as a common reason applications stop. This article does not treat an operating agreement as a document every state requires you to file. If you are writing one for the first time, have an attorney review it before you sign.
A photo ID for the person opening the account. The CIP's examples for an individual include an unexpired driver's license or passport. The same section says that when the bank cannot verify a non-individual customer another way, its procedures must cover information on individuals with authority or control over the account, including signatories.
Who owns the LLC, and who controls it
FinCEN's beneficial ownership page, reflecting a final rule issued August 11, 2026 and effective August 14, 2026, says U.S. companies are exempt from beneficial ownership information reporting and are no longer required to file BOI reports. A domestic LLC does not file a BOI report with FinCEN as a step in opening a bank account. Foreign companies registered to do business in the United States can still have reporting duties. The details are on FinCEN's page, and we wrote up the reporting change in BOI reporting is over for U.S. LLCs.
The bank can still ask who owns and controls the LLC. A separate regulation, 31 CFR 1010.230, requires covered financial institutions to keep written procedures reasonably designed to identify and verify the beneficial owners of legal entity customers, and to identify those owners when a new account is opened, unless an exclusion in that section applies. A legal entity customer includes a limited liability company created by the filing of a public document with a secretary of state. Under that rule, a beneficial owner means each individual who, directly or indirectly, owns 25 percent or more of the equity interests, and one individual with significant responsibility to control, manage, or direct the company. The regulation's examples of that second person include a president and a managing member. The bank may collect this on its own certification. That certification is the bank's customer due diligence. It does not file a BOI report.
Owners who heard that BOI reporting ended for U.S. companies sometimes leave the bank's ownership form blank. The form is still the bank's customer due diligence under 1010.230.
FinCEN has warned about fraudulent letters that demand payment to file beneficial ownership information, including mail that cites a "Form 4022" or "Form 5102." FinCEN says it does not have those forms, and that there is no fee to file BOI directly with FinCEN. A letter telling a U.S. LLC it must pay someone to file a BOI report is not something to answer with a bank account number.
Mistakes that send you home
The approval email, and nothing else
The email shows that a filing was received or accepted. It is not the articles, and it is not a certified copy. Elena had the screenshot. The banker asked for the document.
An EIN issued to a name the articles do not use
The IRS instruction is to use the name on the formation document. If the EIN was issued to "Elena Bakery" and the articles say "Elena Bakery LLC," the banker is going to notice. Fix the mismatch before the appointment, with the IRS or with the state, depending on which record is wrong. A CPA or the IRS business line can tell you which record to correct. This article cannot.
Only the registered-agent address
Legal notices go to the agent. The bank is asking where the business operates. Listing only the agent's mail drop is a frequent reason the application pauses.
The wrong EIN assumption
One version is "a single-member LLC is not allowed to get an EIN." The IRS page says the opposite when a bank account is the reason. The other version is "the IRS requires an EIN for every LLC, no matter what." The single-member page draws a narrower line for a disregarded LLC with no employees and no excise tax. Either assumption can send you to the branch with the wrong paper, or with no paper.
Treating the bank's ownership form as a FinCEN filing
Giving the certification to the banker does not file a BOI report. Refusing to fill it out, because U.S. companies are exempt from FinCEN reporting, leaves the bank without the information 1010.230 tells it to collect.
A signer the agreement never names
Dad is at the bakery. The agreement says only Elena may open accounts, or nobody has signed the agreement at all. The signature card and the company document then disagree. Bring the signed agreement, and bring the person it authorizes, or amend the agreement before you go. Have an attorney look at an amendment before you rely on it.
Before you book the appointment
Form the company with the state first, then apply for the EIN on the IRS site if you need one or the bank asked for one. Save the confirmation the day it arrives. If it is already lost, use one of the three confirmation methods above before the appointment, not from the parking lot.
Ask the branch for its checklist a few days ahead. Banks add items. Some want a certified copy. Some want a good-standing certificate dated close to the meeting. Some want a short resolution that names the signer. The CIP examples do not list a resolution. When a bank asks for one, it is usually trying to see the same thing an operating agreement's signature section shows: who may bind the company.
Bring the signer's unexpired photo ID, the formation document, the EIN confirmation, and a signed operating agreement if you have one. Write down anyone who owns 25 percent or more, and the one person who manages the company, with the identifying details the bank's form asks for. Give that information to the bank. Do not email it to a return address you have not checked.
If the company is out of good standing because a filing was missed, order the status letter after the state will actually issue a clean one. Reprinting a refused certificate does not change the state's record.
A full folder still does not mean the account will open. The CIP tells the bank what to do when it cannot form a reasonable belief that it knows the customer's identity, including when not to open the account. Underwriting and the bank's own risk rules still apply. Nothing on this page is an approval, a funding promise, or a statement that your LLC is in compliance.
How Vermilion Vitez can help
If the LLC already exists and the missing pieces are the certified articles, a current good-standing certificate, a signed operating agreement, and a path to the EIN letter, that is the Bank-Ready Pack. The price on the page is $162.50 per entity. State fees for the two state documents are charged at cost on top of that. Of the $162.50, $80 is the certified copy of the articles and $82.50 is the certificate of good standing. The operating agreement, filled in from the answers on the form, and an EIN letter guide are included. The guide covers where a CP 575 lives and how to request Letter 147C if the original is gone, plus a cover checklist for the appointment. We order the certificate when you order the pack so the date is close to the day you need it.
Bank-Ready Pack
- Certified articles, $80 plus the state fee
- Certificate of good standing, $82.50 plus the state fee
- Operating agreement and EIN letter guide included
If the LLC is not formed yet, the bank has nothing to match to a state record, and the IRS says to form the entity before the EIN application. Start with LLC formation. How it works and pricing are the pages for the filing itself. The pack comes after the state has a record.
Common questions
What does a bank have to collect before it opens an account?
Under 31 CFR 1020.220, a bank's customer identification program has to obtain, before the account opens, the customer's name, an address, and an identification number. For an individual, that includes a date of birth. For a U.S. person, the identification number is a taxpayer identification number. For a customer that is not an individual, the address in the rule is a principal place of business, a local office, or another physical location. A bank may have a procedure for a customer who has applied for a taxpayer identification number and has not received it yet. The rule does not require every branch to open the account on an application receipt.
Does a single-member LLC need an EIN to open a bank account?
The IRS says a disregarded single-member LLC with no employees and no excise tax liability does not need an EIN for federal tax purposes, and that the same LLC can obtain an EIN if a bank account or state tax law requires one. An IRS newsroom note dated August 10, 2026 says many banks require an EIN to open a business bank account. An LLC needs an EIN if it has employees or certain excise taxes, and a multi-member LLC is classified as a partnership unless it elects corporate treatment. Ask a CPA which description fits before you rely on one sentence.
Does my domestic LLC have to file a FinCEN BOI report before the bank will open an account?
No. FinCEN's final rule, issued August 11, 2026 and effective August 14, 2026, exempts U.S. companies from beneficial ownership information reporting. A domestic LLC does not file a BOI report with FinCEN in order to open a bank account. The bank may still ask who owns and controls the company under its own customer due diligence procedures, 31 CFR 1010.230. That bank form is not a FinCEN filing.
Will the bank ask for an operating agreement?
Many banks do. The customer identification rule's examples of documents that show a non-individual exists include certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument. An operating agreement is not in that list. Banks still ask for a signed one because it names who may open the account and sign. This article does not treat an operating agreement as a document every state requires you to file.
Can I use my registered agent address as the business address on the application?
Usually the bank wants the address where the business operates. For a customer that is not an individual, 31 CFR 1020.220 describes the address as a principal place of business, a local office, or another physical location. A registered-agent address is where legal notices go. Our Bank-Ready Pack page says many banks check the operating address.
What if I lost the IRS letter that assigned the EIN?
The IRS lists three ways to confirm an EIN: request an entity transcript, download a digital CP 575 in a Business Tax Account if you are eligible, or call the business and specialty tax line at 800-829-4933 and request Letter 147C. The IRS says a digital CP 575 can stand in for the original CP 575 notice series and for Letter 147C. You can use a newly assigned EIN immediately for most needs, including opening a bank account, and the IRS says to wait up to two weeks before it will pass TIN matching or before you e-file or pay electronically.
Does a complete folder mean the bank will open the account?
No. The customer identification rule tells the bank what to do when it cannot form a reasonable belief that it knows the customer's identity, including when not to open the account. A full folder answers the usual document request. It does not decide underwriting, and it is not a promise of approval.
Bring the formation document, the EIN confirmation, a photo ID, and a signed operating agreement if the bank asked for one. A domestic LLC does not file a FinCEN BOI report to get in the door. The bank may still want its own ownership certification, and the state may still need to show the company is active.
The appointment is already on the calendar
Put the certified articles, a current good-standing certificate, and a signed operating agreement in one pack.
Bank-Ready Pack is $162.50 per entity, plus state fees at cost. If the company is not formed yet, file that first. The bank matches the name to a state record.
Bank-Ready Pack: $162.50 + state fees
Certified articles, a certificate of good standing ordered when you pay, a pre-filled operating agreement, and an EIN letter guide.
Build the pack No LLC on file yetForm the LLC first
The state filing has to exist before the EIN application and before a bank can match the legal name.
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