I know this is a pretty broad question, but I was wondering what documentation some of you you use to verify a business. I know that you do not have to verify account signers. We use a program called Identification Manager where you input information, and it tries to match it up against public information. When verifying an entity, it seems to me that you would not be able to use an SS-4, or application for EIN, to verify the entity, because it is an application. If you use an SS-4 and the account happens to be a loan, how do you know you've verified that entity with just an application. Some businesses do not have articles of incorporation if they are not incorporated. I am not sure what else is available to us with the name and EIN number on it. Especially with funds leaving a bank, it looks like one would verify if not all, as much information as possible. I know that we are not required to verify all information on a customer, just enough to form a reasonable believe that we know who he or she is. I was just wondering what some of you do in these situations.

If the entity is incorporated, we use their articles of incorporation and verify them against the filings of the Secretary of State. As for the EIN number, usually they will have provided 3yrs tax returns which would have the number. If the organization is not incorporated, we require documentation from the group, usually minutes from the last meeting. We also use non-documentary methods of verification such as verification through ID programs, inspection of business, follow up thank you letter, etc.

We get Articles of Incorporation from the State, and verify them on the state records; Corporate Resolution, Operating Agreement, if applicable, etc;
under our policy we also CIP all signers.

What if you have an entity that has just recently applied for an EIN#, and all they have is the application for EIN. However, they are here in front of you and are wanting a loan. If the company is not a corporation, what else would verify the EIN #, and would you fund the loan? We usually look at loans as riskier simply because the funds have left the bank. There is no recourse if we can't get the information we need up front. It's not like we can close the account.

Hmmm, I don't know that I would make a loan to such a new "entity". Even after they have applied for EIN with SS-4 they should be able to provide documentation from IRS stating that number belongs to that entity. Does your software system do a TIN certification?

The EIN application should be sufficient, providing that you know the principals behind the new entity.
If the principals are unknown to you, then I think you have reason to pause.