Need help fast. I just discovered several accounts in our bank with out SSN. Most of them are old and are such as: ABC Cemetary Fund, Boy Scout Troop #, Class of 1949, etc. These small clubs are not going to have proper #'s. What is allowed with this type of account?

As of tax year 2007 - reporting 2008 - these little non-profits will need to apply for an EIN. You can refer to the irs website for more information. As for the IRS - if you report anything on a 1099 and the name and TIN doesn't match, you will be fined and the information sent back for correction.

Has there been a new ruling?

From the IRS website - click on the Charities and Non Profits tab.

New Electronic Filing Requirement for Small Tax-Exempt Organizations - Annual Electronic Notice — e-Postcard (Form 990-N)

Beginning in 2008, small tax-exempt organizations that previously were not required to file returns may be required to file an annual electronic notice, Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations not Required To File Form 990 or 990-EZ. This filing requirement applies to tax periods beginning after December 31, 2006.

Small tax-exempt organizations, whose gross receipts are normally $25,000 or less, are not required to file Form 990, Return of Organization Exempt From Income Tax, or Form 990-EZ, Short Form Return of Organization Exempt from Income Tax. With the enactment of the Pension Protection Act of 2006 (PPA), these small tax-exempt organizations will now be required to file electronically Form 990-N, also known as the e-Postcard, with the IRS annually. Exceptions to this requirement include organizations that are included in a group return, private foundations required to file Form 990-PF, and section 509(a)(3) supporting organizations required to file Form 990 or Form 990-EZ.

The IRS will mail educational letters starting in July 2007 notifying small tax-exempt organizations that they may be required to file the e-Postcard. The IRS is developing an electronic filing system (there will be no paper form) for the e-Postcard and will publicize filing procedures when the system is completed and ready for use.

The PPA requires the IRS to revoke the tax-exempt status of any organization that fails to meet its annual filing requirement for three consecutive years. Therefore, organizations that do not file the e-Postcard (Form 990-N), or an information return Form 990 or 990-EZ for three consecutive years, will have their tax-exempt status revoked as of the filing due date of the third year.

If you would like additional information about this new filing requirement, including notification when the filing system is ready, or information about other new developments, subscribe to Exempt Organization’s EO Update, a regular e-mail newsletter that highlights new information posted on the Charities pages of irs.gov.

Thank you guys so much. This is exactly what I was looking for. Hope all had a great 3-day weekend!

Another question? In review, we have one customer (husband and wife) who refused to provide SSN back in 1962 when opening account. He has never provided it and will not. He has regular DDA (no interest paid). This couple and family are known to our community and to our bank. Are there any provisions to exempt them from providing SSN's? I know under CIP, it requires new accounts to provide but what about 45 year old accounts?

He can get away with it until he opens a new account.
Accounts prior to October 1st 2003 are exempt unless your policy says otherwise.

Thank you!