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Can we create a separate account for checks made out to a subgroup of an organization? The organization and the subgroup both operate and report under one TIN. – IBA Compliance Connection

Can we create a separate account for checks made out to a subgroup of an organization? The organization and the subgroup both operate and report under one TIN.

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Based on the facts that you have provided, we do not see an issue with creating a separate account for the subgroup. We do recommend having an officer of the subgroup (if there is one) provide a signed statement conferring signing authority to the parent entity and specific individuals in the parent entity for the bank account and all checks, instruments, notes, etc. on behalf of the subgroup (if the subgroup has a board, this statement should be a resolution of the board). Also, you should ensure that the parent entity’s authorized individuals are provided signature authority for the subgroup’s account when it is opened.