Answer by John Burnett: The organization must have an EIN to comply with IRS and state regulations, and you must obtain it to be in compliance with the CIP regulations.
Suggest to the organization they contact whoever does their payroll or accounting. They will have a record of the EIN for the organization. Another source would be the quarterly 941 forms they file on withheld taxes or annual charitable organization reports they file with the state.
If the account was opened after 9/30/03, you must either get their EIN or close the account. If they for some outlandish reason don't have an EIN, they can apply for one. If they can't produce it within 30 days, find an exit for this account.
Answer by Ken Golliher: Ditto John, your customer needs the number. A couple more points:
- Per the instructions to the SS-4, your customer can call the IRS Tele-TIN number, 800-829-4933, to verify an EIN or find out whether they have one. (You cannot make the call on their behalf.)
- The notation of "exempt" on the W-9 or its equivalent is a certification that they are exempt from information reporting. That certification would only be relevant to an interest-bearing account and does not excuse them from obtaining an EIN.
First published on BankersOnline.com 9/6/04