The practical walkthrough, sourced from IRS Publication 1828
This is one of the first practical walls a new ministry runs into. You've settled on 508(c)(1)(A) status, you're not filing Form 1023, and then you sit down at a bank and realize almost nothing online actually walks through what the bank wants to see. Most of what's written about 508(c)(1)(A) stops at the tax theory. Here's the part that comes after.
Whether or not your church ever applies for IRS recognition, there's one number you need before you can open an account: an Employer Identification Number (EIN). This isn't specific to 508(c)(1)(A) churches; it's true for every tax-exempt organization, church or not, and the IRS says so directly.
"Every tax-exempt organization, including a church, should have an employer identification number whether or not the organization has any employees. There are many instances in which an EIN is necessary. For example, a church needs an EIN when it opens a bank account ..."
An EIN is obtained by filing Form SS-4, and this is one of the few places where 508(c)(1)(A) status genuinely simplifies things: you don't need a determination letter, an accepted Form 1023, or any other IRS recognition first. A church can request an EIN as soon as it exists as an organization. The IRS's current EIN application page is here: irs.gov, Get an Employer Identification Number.
Generally, no. Most banks open a nonprofit or church account on the strength of your EIN plus your organizing documents, not a federal tax determination letter. That said, individual bank policy varies, and some banks, particularly larger institutions with more layers of compliance review, may ask for more documentation before they're comfortable, especially with a brand-new organization that has no operating history yet. This is a business decision each bank makes on its own, not an IRS requirement, so it's worth calling ahead and asking your specific branch what they'll want to see before you show up.
Every bank needs the same two basic things regardless of entity type: proof the organization legally exists, and proof of who's authorized to act for it. In practice, that tends to mean:
None of this is unique to being a church, and none of it depends on whether you filed Form 1023. It's the same basic packet most nonprofits bring to a bank, and confirming the exact list with your chosen bank ahead of time can save a wasted trip.
Here's something worth knowing before you walk in, not after. Banks, like the IRS, tend to look more closely at an account controlled entirely by one person or one household, with no outside board and no separation between the organization's money and a founder's personal finances. This isn't a 508(c)(1)(A)-specific problem. It's the same pattern that has shown up in tax court when a church's exemption itself gets challenged.
In one case, a California organization's only voting members, ever, were a husband, wife, and their adult son, who also made up the entire board. Of about $61,000 the organization received in donations in a single year, the Tax Court found that at least $37,000 went back to the family directly, recorded as a "living allowance," a "parsonage allowance," medical costs, and travel, including a trip to Europe, with nothing shown for outside programs. The court wasn't satisfied the organization's earnings hadn't benefited the family privately, and the exemption was denied.
Bubbling Well Church of Universal Love, Inc. v. Commissioner, 74 T.C. 531 (1980)
That case was about the IRS challenging tax-exempt status, not a bank declining an account. But the underlying pattern, one household with total, unchecked control of the money, is exactly what makes both an IRS examiner and a bank's compliance officer slow down and ask more questions. A board that includes people outside your immediate family, with real authority and a real say in the finances, tends to make every part of this process, banking included, move faster and draw less scrutiny.
However you filed, the underlying recordkeeping duty doesn't change. The IRS is explicit that this obligation exists whether or not you ever sought official recognition:
"All tax-exempt organizations, including churches and religious organizations (regardless of whether tax-exempt status has been officially recognized by the IRS), are required to maintain books of accounting and other records necessary to justify their claim for exemption in the event of an audit."
In practice, that means running every dollar of church income and every dollar of church expense through the church's own account, not a personal one, and keeping the two completely separate. It also means keeping the $250 donation-acknowledgment rule in mind from day one:
"A donor can't claim a tax deduction for any single contribution of $250 or more unless the donor obtains a contemporaneous, written acknowledgment of the contribution from the recipient church or religious organization."
A dedicated church account makes that recordkeeping far simpler than trying to reconstruct it later out of a personal checking account.
Once the bank account itself is open, most ministries also want a way to accept online gifts, whether that's a dedicated giving platform, a payment processor, or a simple card reader for in-person offerings. These services generally ask for the same underlying proof a bank does: your EIN, your organization's legal name matching that EIN exactly, and often a linked bank account in the organization's name rather than a personal one. Some platforms ask an extra question or two about nonprofit or religious-organization status during signup; having your EIN confirmation letter and governing document on hand before you start that signup tends to make it move faster.
It's worth resisting the temptation to set up giving tools under a personal account "just to get started faster." The same recordkeeping and inurement concerns that apply to a bank account apply here too, and untangling commingled funds after the fact is far more work than opening things correctly from day one.
A few patterns come up often enough to flag directly:
No. An EIN, obtained through Form SS-4, is what a bank needs; it doesn't require an accepted Form 1023 or an IRS determination letter first.
By filing Form SS-4, Application for Employer Identification Number, with the IRS. This can typically be done online through the IRS's EIN application page, and it doesn't require the organization to have IRS tax-exempt recognition first.
We'd strongly caution against it. Mixing personal and church funds makes the recordkeeping the IRS requires much harder to produce, and it mirrors the pattern courts have pointed to when denying exemptions on private-inurement grounds.
Some banks might, though it isn't a universal requirement. Policy varies by bank and by how established your organization appears. It's worth calling your specific branch ahead of time to ask.
It doesn't automatically disqualify anything, but it's the pattern that has drawn the most scrutiny in past tax court cases and, practically, tends to draw more questions from banks as well. A board with members outside the immediate family generally makes both processes smoother.
The plain-English basics of the rule that lets churches skip the exemption application.
A side-by-side look at applying for a determination letter versus relying on automatic recognition.
Estimate formation fees, registered agent, EIN, and first-year incidentals by state.
See what an entity actually costs to form and maintain, state by state, five years out.