Good Morning!

1. Feature: Opening or Moving a Bank Account for an LLC is Not Easy Anymore (4 min)

2. From the Archive: From Family LLC to Family Office: A Roadmap for Everyone (Read it here)

3. Dear TCoL: Can I Use a UPS Store for my LLC Office Address?

Start Monday with clarity by preparing your week in advance.

-TCoL

Missed our last feature article? You formed an LLC. Now what? (Read it here)

Banks are stricter today than most new owners expect. Compliance duties increased after pandemic-era fraud, privacy concerns, and a steady rise in online scams. Financial institutions now verify identities and business details with real rigor before they let money in the door. It can slow you down and be frustrating.

This article, whether you need it now or later, should help you be prepared for the “new normal” of opening bank or brokerage accounts.

Why they ask for so much

Banks and brokerage companies must follow two core federal rules. The Customer Identification Program rule requires them to collect and verify key identity data for anyone opening an account. The Customer Due Diligence rule requires them to identify and verify beneficial owners of legal entity customers. These rules live inside the Bank Secrecy Act framework and are not optional.

Fraud numbers explain the vigilance. The FBI reports internet crime losses of more than $16 billion in 2024. The FTC reports another $12.5 billion in consumer fraud the same year. Banks see the fallout daily, so they scrutinize new accounts with a heavy hand.

A quick note on FinCEN reporting

You may have heard about the Corporate Transparency Act and beneficial ownership reporting to FinCEN. In March 2025, Treasury issued an interim final rule that exempted domestic entities from BOI reporting while keeping obligations for certain foreign entities. Even with that change, banks still collect beneficial owner information at account opening under the existing Customer Due Diligence rule.

What the bank will ask about you

Expect the bank to gather four pieces of identity information for each person who will be a signer. Full legal name. Date of birth. Residential or business address. An identifying number such as a Social Security Number or passport number. The bank must verify this information using documents or non-documentary methods. Bring a government-issued photo ID for every signer. No ID means no account.

For the company, expect questions about your business model, expected transaction volumes, incoming payment methods, outgoing payment methods, main suppliers, and primary customers by type. The bank is building a profile to monitor for unusual activity later.

What the bank will ask about your owners

Banks will ask for each beneficial owner at 25 percent or more and one control person. This is the standard under the Customer Due Diligence rule. Each listed person provides the same identity details that signers provide, even if a listed owner is not a signer. Prepare names, dates of birth, addresses, and identifying numbers.

Subscriber stories to learn from

A reader recently formed an LLC using a virtual office provider. They bought both registered agent services and a virtual office address from the same company. A large national bank refused to open the account because the registered agent address and the company address were the same. The bank ultimately found a work-around to their internal requirements after the customer agreed to use their home address as the company address for the bank’s records (the company office didn’t have to be changed).

Another reader tried to open a brokerage account for a new multi-member LLC at a top five online broker. To move forward, the brokerage company required a written initial resolution authorizing the account, a signed operating agreement, a cap table showing all members and their ownership percentages, and proof of a physical address for the LLC supported by a lease or utility bill in the LLC’s name. Without that level of detail, the application would not have moved forward.

These stories are not outliers. They reflect what many LLC owners now face. The lesson is to expect more questions, not fewer, and to prepare documentation that goes beyond your formation packet.

Documents to have ready for an online application

Prepare digital copies in PDF format. Clear scans save time. Most national banks ask for the following items for an LLC:

1. IRS EIN confirmation letter or SS-4 approval equivalent from the IRS website

2. Articles of Organization or Certificate of Formation filed with your state

3. Operating Agreement that shows member names and management structure

4. Initial resolution authorizing account opening and identifying signers. If you need one, see our prior article: The Initial Resolution You Need After LLC Formation.

5. Certificate of Good Standing if the LLC is older than a year

6. Any trade name filing if you operate under a DBA

7. Cap table if there are multiple members, showing individual ownership interests totaling 100%

8. Physical business address evidence such as a lease or utility bill in the name of the LLC

9. Government photo IDs for signers and beneficial owners, ready to upload

What to bring for an in-person appointment

Take the same documents in paper form plus your laptop or phone with digital copies. Bring your state registration if you formed in another state and registered as a foreign LLC in the state where the bank is located. If you are adding a new account at a bank you already use, bring your current debit card and prior account details to speed up internal verification.

Special situations that trigger extra questions

If you work in a higher-risk category such as money services, crypto-related activity, or cross-border payment facilitation, expect enhanced due diligence. That can include additional ownership documentation, program descriptions, licenses, and compliance policies. If you use a virtual address service, expect the bank to confirm a physical operating address.

Simple steps that speed up the process

Schedule before you apply. Use the bank’s appointment link and ask for a business banker that handles new accounts. Confirm the document list for your LLC type. Large banks post checklists with small variations.

Complete your Operating Agreement. Make sure it states who can open and manage accounts. If the agreement is silent, prepare a short, written resolution signed by members. Bring membership percentages and titles. The bank will enter these into its beneficial owner record. Need an operating agreement? See our prior article: Your LLC Is Missing Its Most Important Document.

Is your membership interest owned by your revocable trust? If so, bring a copy of your revocable trust.

Collect owner IDs early. Owners who are not present will slow the process. Ask the banker whether remote identity verification is allowed and how to upload securely.

Account opening thoughts

Opening or moving an LLC bank account takes preparation and patience. The days of a quick signature and starter deposit are gone. Banks now want formation documents, ownership records, operating agreements, and physical address proof. They also want a clear picture of who you are, who owns your company, and how you will use the account.

Prepare in advance and bring more than the minimum.

Spend less time waiting for approval and more time running your business.

Dear TCoL: Can I Use a UPS Store for my LLC Office Address?

Question: This is a great newsletter!! Question, can you use a UPS Store physical address for an LLC?

Thanks so much!

Answer: Yes, UPS Stores will contract with you for various virtual office services and let you use their physical address, which is an acceptable address for your LLC in most states.

Where you might run into a problem later is if you try to register a vehicle or trailer in your LLC name. Some states (Wyoming DMV, in particular), do not like virtual offices if you want to title a vehicle. We know of an instance where Wyoming DMV would not title a cargo trailer for an out of state LLC owner unless the owner could produce a commercial lease or a utility bill for their Wyoming virtual office address.

Hopefully, you are in Florida or Texas.

Have an interesting business question and need a free bit of advice? Send your question to [email protected]. No confidential info, please!