Payment Accounts for Family Office SPVs

A family office SPV bank account (the payment account for the co-invest vehicle) is a deposit account titled in the SPV's legal name, tied to that vehicle's IRS EIN. It is where subscriptions land, the co-invest wire leaves, expenses clear, and exit proceeds return. It is not the family's operating checking account, not a personal account of a principal, and not a shared "warehouse" for three deals.

This is operational guidance for family offices, RIAs, and counsel — not legal, tax, or banking advice. A bank's own CIP, BSA/AML program, and risk rating decide what extra documents they want. Confirm current EIN rules on IRS.gov and current CIP text on eCFR before you send a file. For structure context, start with family office co-invest SPV and the general SPV bank account: EIN, KYC, and what banks ask.

Why the co-invest SPV needs its own payment account

A family office co-invest SPV exists to isolate one name: liability, K-1, transfer rules, and exit. That isolation fails the moment deal cash runs through another pile.

Liability and audit trail. The Delaware LLC is a separate legal person. Mixing the co-invest wire through the family's main operating account, a principal's personal account, or a multi-deal clearing account is how you lose the wire map that counsel and auditors ask for after a dispute, a broken-deal expense, or a distribution fight.

K-1 hygiene. A multi-member LLC taxed as a partnership files Form 1065 and furnishes Schedule K-1s. Capital accounts and distributions should match cash that actually moved through this vehicle. Journaling "we wired from Holdco and will true-up later" is how K-1 season becomes archaeology. See SPV K-1s and taxes.

Side-by-side with the fund. The lead fund has its own custody and capital accounts. The co-invest is a separate security in a separate issuer. Paying both from one family account collapses the side-by-side story the IC memo sold.

Bank expectations. Banks open accounts for their customer — the LLC — under CIP. They do not treat "we usually wire from the family office OpCo" as a substitute for an account in the SPV's name.

Allocations banking (fetched 4 Sep 2026) states the product rule: a dedicated account is opened for every SPV and fund as part of onboarding, alongside entity formation, legal templates, investor onboarding, and close. It is not a standalone banking price. Standard SPV is $9,950 one-time, Premium SPV is $19,500 one-time, and Fund is $19,500/year on the published fees page; platform carry is 0%; additional fees may apply.

EIN first, then CIP

Banks treat a U.S. entity's identification number as its taxpayer identification number — for an LLC, the EIN. The IRS Apply for an EIN online page (fetched 4 Sep 2026) is the primary source:

• The IRS issues EINs for free. Do not pay a third-party site.

• Form the entity with the state before you apply. Applying before the Certificate of Formation exists can delay the application.

• Complete the session in one sitting; it expires after inactivity.

• One EIN per responsible party per day.

• Print the confirmation letter and keep it with the closing binder.

A single-member family SPV that is disregarded for federal income tax may still need an EIN for banking. Classification is a tax-advisor call; the bank still wants a TIN for the account customer. Form the Delaware LLC first, then apply.

31 CFR 1020.220(a)(2)(i)(B) (fetched 4 Sep 2026) lets a bank open an account for a customer that has applied for, but not yet received, a TIN, if the CIP confirms the application was filed first and the number is obtained within a reasonable time after opening. That is an exception, not a workflow. For a co-invest SPV, get the EIN, then fund.

What CIP requires — and what family offices usually add

Under 31 CFR 1020.220 (fetched 4 Sep 2026), a bank must implement a written CIP that lets it form a reasonable belief it knows the customer's true identity. For a person other than an individual, the floor identifying information collected before opening is:

1. Name.

2. Address — a principal place of business, local office, or other physical location (not a P.O. box as the only address).

3. Identification number — for a U.S. person, a taxpayer identification number.

Verification may be documentary, non-documentary, or both. For entities, documentary examples include certified articles of incorporation (Certificate of Formation for a Delaware LLC), a partnership agreement / LLC agreement, or a trust instrument. Identifying information is retained for five years after the account is closed.

CIP is a floor. Family-office SPVs typically add:

• Certificate of Formation matching the account title character-for-character.

• EIN confirmation letter.

• Operating agreement naming who may open accounts and wire.

• Resolutions naming authorized signers (often family-office principals or a management company).

• Government ID for signers / control persons when the bank's risk rating requires it (31 CFR 1020.220(a)(2)(ii)(C)).

• Source-of-funds answers: capital from family holdco or club members, one co-invest wire out, later distribution.

• Trust or holdco ownership chart when the member is not a natural person — so the bank can see who controls the customer.

Investor-level KYC for other families in a club SPV is a parallel track. The bank is identifying its customer (the LLC). Confusing the two files is how you send LP passports when the bank asked for the Certificate of Formation.

How Allocations folds banking into the co-invest path

The live banking page (fetched 4 Sep 2026) places the account in a six-step path: deal room, entity formation, bank account, legal templates, onboard investors, close and wire. That order is practical. You cannot collect co-invest cash into an account that does not exist, and you should not exist as an LLC with no place to hold it.

Banking is part of onboarding, not a separate SKU on fees. As of 4 Sep 2026: Standard SPV $9,950 one-time (up to 35 investors, one close, VC, five-year term; +$100 per extra investor); Premium SPV $19,500 one-time (up to 50 investors; extra closes $2,000); Fund $19,500/year; platform carry 0%; additional fees may apply. Distribution pricing is separate and hits at liquidity.

This article does not name a bank partner. Allocations' /banking page, fetched 4 Sep 2026, does not name one either. If a partner name matters to an IC memo, verify it on allocations.com when you write the memo. Structure the vehicle on the SPV product page; keep family-office use-case context on family office co-invest SPV.

Keep the payment account boring on purpose

Match expected-activity answers to the documents. A single-asset co-invest that takes member capital, buys one security, sits, then distributes is easier to explain than a vehicle that pays operating vendors or moves money among affiliates.

The customer is the LLC. Signers are the authorized persons named in the resolution. For the EIN, send the IRS letter, not a screenshot from a third-party site. After exit and Delaware cancellation, close the account. Do not recycle it for the next co-invest.

Skip the dedicated payment account and you spend close week reconstructing wires. Wait on the EIN and you spend it refreshing a CIP exception. Formation, EIN, account, then subscriptions — the same sequence as any other Allocations SPV, applied to the family office co-invest box.

Why does a family office SPV need its own payment account?

Because the SPV is a separate legal entity. Subscriptions, the co-invest purchase, expenses, and distributions should run through an account titled in the LLC's name under the SPV's EIN. Mixing cash through the family OpCo breaks the isolation the co-invest SPV was formed to create.

Do we need an EIN before the bank opens the account?

Usually yes. CIP requires a U.S. entity TIN before opening, with a narrow exception if the EIN application is already on file (31 CFR 1020.220(a)(2)(i)(B)). Form the Delaware LLC first, then apply on IRS.gov at no charge.

Is Allocations banking a separate fee for family office SPVs?

No. The live /banking page (fetched 4 Sep 2026) treats a dedicated account as part of SPV and fund onboarding, paired with published Standard, Premium, and Fund prices on /fees. Platform carry is 0%. Additional fees may apply; banking is not a standalone SKU.

How is bank CIP different from KYC on other families in a club SPV?

CIP identifies the bank's customer — the SPV — under 31 CFR 1020.220. Investor KYC/AML identifies members who subscribe. Run both. Do not send member passports when the bank asked for the Certificate of Formation.

Where should we read about the co-invest structure itself?

Family office co-invest SPV for isolation, docs, and side-by-side mechanics; SPV bank account: EIN, KYC, and what banks ask for the general banking file; /banking for the product surface.