No, we are not aware of a requirement to obtain a separate EIN for an informal fundraising account.

We do note that it is possible for fundraising accounts to obtain separate EINs, even when the account holder is not incorporated as a not-for-profit corporation. The IRS’ online EIN application expressly states that various informal groups and organizations may obtain EINs, including: Block/Tenant Associations, Community or Volunteer Groups, Memorial or Scholarship Funds, PTA/PTO or School Organizations, Social or Savings Clubs, Sports Teams – and more. If an individual or group does not fit into one of the enumerated categories, it can fill in the “Other” designation on the EIN application.

For more information on “benefit” accounts and possible charitable trust requirements, we recommend reviewing this IBA Q&A.

For resources related to our guidance, please see:

• IRS Online EIN Application Assistant (Permitting organizations to apply for EINs as Block/Tenant Associations, Community or Volunteer Groups, Memorial or Scholarship Funds, PTA/PTO or School Organizations, Social or Savings Clubs, Sports Teams and more, under “Additional Types.”)