SPV Bank Account: EIN, KYC, and What Banks Ask For

An SPV bank account is a deposit account in the vehicle’s legal name, tied to the SPV’s IRS EIN. Banks collect CIP data under 31 CFR 1020.220 — name, physical address, and taxpayer identification number — before they treat the account as open. Allocations includes a dedicated account per SPV or fund as part of onboarding, not as a separate SKU.

This is operational guidance for GPs 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 IRS EIN rules on IRS.gov and current CIP text on eCFR before you send a file.

The vehicle needs its own account

Mixing deal cash through a GP operating account, a personal account, or a “warehouse” account for several SPVs is how you lose audit trails, scramble K-1s, and create commingling arguments. Each Delaware LLC is a separate legal person. Capital calls, close wires, expense payments, and exit distributions should hit an account titled in that LLC’s name.

Allocations banking (fetched 2 Sep 2026) states the product rule: a dedicated account is opened for every SPV and fund, with banking sitting in the same onboarding path as 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; additional fees may apply. Platform carry is 0%.

A dedicated account also matches how SPV administration is supposed to work: one vehicle, one cap table, one set of wires. If you are still choosing a structure, start from the SPV product page rather than opening a personal account “until formation catches up.”

Get the EIN before CIP can finish

Banks treat a U.S. entity’s identification number as its taxpayer identification number — for an LLC, the EIN. The IRS Apply for an employer identification number (EIN) online page (fetched 2 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. If you apply before the Certificate of Formation exists, the IRS says the application may be delayed.

• Complete the session in one sitting; it expires after 15 minutes of inactivity.

• One EIN per responsible party per day.

• You need the responsible party’s SSN or ITIN (or, if you are a third-party designee, signed authorization).

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

31 CFR 1020.220(a)(2)(i)(B) (fetched 2 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 deal SPV, get the EIN, then fund.

What 31 CFR 1020.220 actually requires

CIP is a Treasury/FinCEN bank rule, not a “startup banking checklist” invented by platforms. Under 31 CFR 1020.220 (fetched 2 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.

Date of birth is an individual field. It applies to signers when the bank is identifying a natural person, not to the LLC itself.

Verification may be documentary, non-documentary, or both, within a reasonable time after opening. For entities, the regulation’s documentary examples are certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument. A Delaware SPV file maps cleanly onto that list: Certificate of Formation (certified copy from the Division of Corporations), LLC agreement, and EIN letter.

The bank must also keep CIP records. Identifying information is retained for five years after the account is closed. Document descriptions and verification notes are retained for five years after the record is made. CIP further requires comparison against designated government lists and customer notice that the bank is collecting identity information.

CIP is a floor. A bank’s BSA/AML program and its risk rating of private-fund vehicles will add items. That is normal. It is not a sign the SPV is “non-compliant.”

What banks typically add on top of CIP

Expect a file that looks like a miniature onboarding room, not a consumer checking application:

• Certificate of Formation and any name-change or amendment filings, matching the account title character-for-character.

• EIN confirmation letter (CP 575 or the online notice).

• Operating agreement, including who may open accounts, who may wire, and whether two signatures are required.

• Resolutions or a banking addendum naming authorized signers.

• Government ID and, where the bank’s CIP requires it, identifying information for individuals with authority or control over the account, including signatories — 31 CFR 1020.220(a)(2)(ii)(C) addresses additional verification for certain non-individual customers when identity cannot otherwise be verified.

• Source-of-funds and expected-activity questions: capital calls from LPs, one or two portfolio wires, expense payments, later distributions. A single-asset VC SPV with a 5-year term is a simpler activity profile than an operating company.

• Registered-agent address versus principal place of business. CIP wants a physical location. A Delaware registered-agent address is not always enough if the bank wants the manager’s office.

Do not treat this list as a statute. Banks differ. The GP’s job is to have the binder ready so a request does not stall a close.

Investor-level KYC is a parallel track, not a substitute. LPs still complete identity, accreditation, and AML checks to subscribe. That workstream is covered in KYC/AML investor onboarding for SPVs. The bank is identifying its customer — the LLC — and the people who control the account. Confusing the two files is how you send LP passports to a bank that asked for the Certificate of Formation.

How Allocations folds banking into onboarding

The live banking page (fetched 2 Sep 2026) places the account in a six-step path: deal room, entity formation, bank account, legal templates, onboard investors, close and wire. The point of that order is practical. You cannot collect LP wires into an account that does not exist, and you should not exist as an LLC with no place to hold cash.

Banking is part of onboarding alongside formation. It is not priced as its own line on fees. What is priced, as of 2 Sep 2026: Standard SPV $9,950 one-time (up to 35 investors, one close, VC assets, five-year term; additional investors +$100 each); Premium SPV $19,500 one-time (up to 50 investors, multiple closes with one included, $2,000 per extra close, any asset type); Fund $19,500/year (249 VC or 99 non-VC investors, unlimited closes, 30 assets included); capital calls $2,500/call when you tranche; additional fees may apply. Distribution pricing is separate and hits at liquidity.

This article does not name a bank partner. Allocations’ /banking page, fetched 2 Sep 2026, does not name one either. If a partner name matters to your IC memo, verify it on allocations.com at the time you write the memo.

Once the account exists, keep it dedicated through the life of the vehicle: close, expenses, optional additional closes on Premium, capital calls, and eventually the distribution at exit. After cancellation of the Delaware certificate, close the account. Do not recycle it for the next SPV.

Keep the account boring on purpose

Banks rate expected activity. A deal SPV that receives LP subscriptions, pays a single stock purchase, sits, then distributes cash at exit is easier to explain than a vehicle that starts paying operating vendors, taking on debt, or moving money among affiliates.

Write the expected-activity answers to match the documents: one asset (Standard/Premium), VC vs any-asset on the SKU you actually bought, investor cap, and term. If the operating agreement says the manager may only call capital for the stated purpose, do not tell the bank you will run a working-capital facility.

When the bank asks “who is the customer,” the answer is the LLC. When they ask “who can move money,” the answer is the authorized persons named in the resolution. When they ask for the EIN, send the IRS letter, not a screenshot of a third-party EIN mill.

GPs who skip the dedicated SPV bank account spend the close week reconstructing wires. GPs who wait on the EIN spend it refreshing a CIP exception. Do formation, EIN, account, then subscriptions — in that order.

Why does an SPV need its own bank account?

Because the SPV is a separate legal entity. Subscriptions, the asset purchase, expenses, and distributions should run through an account titled in the LLC’s name, under the SPV’s EIN. Allocations opens a dedicated account per SPV or fund as part of onboarding.

Do I need an EIN before the bank will open the SPV account?

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

What documents do banks ask for on an SPV?

CIP’s documentary examples for entities include certified formation documents and the governing agreement. In practice, banks also want the EIN letter, signer IDs, and a resolution naming who may transact. Exact lists vary by bank and are not set out as a single federal form.

Is Allocations banking a separate fee?

No. The live /banking page (fetched 2 Sep 2026) treats a dedicated account as part of SPV and fund onboarding, paired with published Standard, Premium, and Fund prices on /fees. Additional fees may apply to other line items; banking is not a standalone SKU.

How is bank CIP different from LP KYC?

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