Starting a Church & 501(c)(3)
Opening a Church Bank Account: What the Bank Will Ask For
Short answer: bring your filed articles of incorporation, your EIN confirmation, your adopted bylaws, a board resolution naming the account and the authorized signatories, government photo ID for everyone signing, and an assumed name certificate if the church operates under a shorter name. If the branch asks for a 501(c)(3) determination letter you don't have, that's a policy question you can usually resolve, because churches are treated as exempt without applying.
You booked an appointment, brought a folder, and left forty minutes later with a list of three more things. It happens to nearly every plant, and it's almost always because one document in the chain doesn't exist yet rather than because the bank is being difficult.
Here's the full list of church bank account requirements, in the order the documents have to be created, so the appointment happens once. If you're earlier in the process than that, the six documents every new church needs is the wider set this one fits inside.
What the bank will ask for
1. Filed articles of incorporation. Not your draft. The version the state accepted, with the file stamp or the certificate of formation. If you only have the draft you sent in, order a certified copy from the filing office.
2. Your EIN confirmation. The IRS notice issued when the EIN was assigned, or a letter confirming it if the original is lost. The account is opened against the church's EIN, never a person's Social Security number (IRS, Get an Employer Identification Number). If you haven't done this yet, the fifteen-minute EIN walkthrough covers it, and why you need one even with no employees covers why this isn't optional.
3. Adopted bylaws. The bank reads them to confirm who has authority. Bylaws that exist as a file on a laptop but were never adopted at a meeting won't help you here.
4. A board resolution authorizing the account. This is the document plants most often lack. It states that the board resolved to open an account at the named institution, and names the officers authorized to sign, along with any limits. Many banks have their own corporate resolution form; bring your own minuted version as well.
5. Minutes of the meeting that adopted all of the above. Same meeting, usually. Signed by the secretary.
6. Government photo ID for every signatory, plus their addresses, dates of birth and Social Security numbers. This is anti-money-laundering compliance, not curiosity.
7. A certification of who controls the entity. Under customer due diligence rules, banks must identify a control person for legal entity customers, typically an officer with significant responsibility. Nonprofit corporations have no owners, so there's generally no beneficial-owner list to give, but the control-person certification still applies.
8. An assumed name certificate, if the sign says something different from the legal name in the articles.
9. A physical address, phone number and description of activities. Banks ask what the organization does, roughly what its annual receipts and deposit volumes will be, and whether it will receive cash. Answer honestly. A church that says "no cash" and then deposits a cash offering every week triggers exactly the review you'd rather avoid.
When they ask for a 501(c)(3) letter
This is the sticking point, and it has a straightforward answer.
Churches that meet the requirements of section 501(c)(3) are treated as tax-exempt without applying, and aren't required to file Form 1023 to be exempt (IRS Publication 1828, Tax Guide for Churches). A great many churches therefore have no determination letter, and never will.
Branch staff frequently don't know this, because most of the nonprofits they open accounts for do have a letter. What usually works:
- Offer the substitute package: articles showing the exempt-purpose and dissolution language (IRS, Exemption requirements for 501(c)(3) organizations), bylaws, the EIN notice, and the authorizing resolution. That's what the letter would have evidenced.
- Ask to speak to business or nonprofit banking, not the retail desk. The policy answer sits above branch level.
- Ask whether the requirement is regulatory or internal policy. If it's internal policy, an exception process usually exists.
- Try a different institution. Credit unions and community banks with church clients often handle this in one visit. Some denominations also run their own financial institutions.
If a bank insists and you need an account this month, opening it and applying for a determination letter in parallel is a legitimate choice. Just make that decision knowingly rather than because a branch told you it was compulsory.
The controls to set up on day one
The account isn't just a place to put money. It's the church's main financial control, and the settings you choose at opening are the ones you'll still be living with in five years.
Two unrelated signatories, minimum. Not the pastor and the pastor's spouse. The point is that no single household can move money alone.
Dual authorization on outgoing funds above a stated threshold, set in your bylaws or a financial policy and reflected in the account setup.
Separate the person who reconciles from the people who sign. Whoever writes the checks shouldn't be the person who reviews the statement. Have the unopened statement go to a board member who signs nothing.
Restrict debit cards. One card, one holder, a low limit, and receipts required. Multiple cards distributed for convenience is how small churches lose money quietly, and how good people end up under suspicion.
Set online banking permissions deliberately. View-only access for board members who need visibility. Payment initiation for as few people as possible. Approval by a second person.
Turn on alerts. Transaction notifications to two people is a free control that works.
Write the counting procedure before the first offering. Two unrelated counters, both signing a count sheet, deposit matching the sheet, and the sheet retained. Money handled by one person is the origin of nearly every church financial problem, including the ones where nothing was actually stolen and the treasurer couldn't prove it.
How churches get this wrong
Running the church through a personal account "for now." Even for two weeks. It creates a tax problem for the account holder, it's close to impossible to unpick later, and it destroys trust instantly if anyone ever questions it.
Payment apps in an individual's name. Digital giving is fine; digital giving into a person's personal handle isn't. Set the church's giving tools up against the church's EIN and account.
One signatory because it's easier. It is easier. It's also the single riskiest financial arrangement a church can have, and insurers ask about it.
Opening in the wrong name. The account name should match the articles exactly. A mismatch causes problems with donor receipts, grants and eventually a mortgage application.
No resolution on file. When a signatory leaves, the bank wants a resolution to remove them. Churches with no minutes discover this at the worst moment, usually when the departing person is the one who has to cooperate.
Never updating signatories. People move, resign, or are asked to leave. Update the account the same week, and minute it.
A worked example
A plant books a bank appointment for a Tuesday. They arrive with articles and an EIN letter.
The bank asks for bylaws and a corporate resolution. They have neither, because the board has met twice and taken no minutes. The appointment ends without an account, and the launch offering the following Sunday goes into the pastor's personal account "temporarily."
Unwinding that takes four months. The pastor's accountant needs an explanation of the deposits, two donors need corrected receipts, and the board spends a meeting reconstructing what came in and when.
The version that works costs one evening. The board meets, adopts bylaws, elects officers, passes a banking resolution naming two unrelated signatories, and minutes all of it. The following Tuesday the account opens in twenty minutes.
Same church, same week, entirely different first year.
Common questions
Can we open an account before we incorporate?
Generally not as a church. Banks open entity accounts against entity documents. An unincorporated association can sometimes open one, but it requires the association's governing document and a resolution, and many banks won't do it.
Do we need a determination letter?
Not to be exempt, if you meet the requirements as a church (IRS, About Form 1023). You may need one because a bank, landlord, lender or grantmaker asks. That's a practical reason to apply, not a legal one.
How many signatories should we have?
At least two, and usually three or four authorized with any two required for payment. That gives you continuity when someone is away without ever allowing one person to act alone.
Should the pastor be a signatory?
Many churches deliberately keep the pastor off the account entirely. It protects the pastor as much as the church, because a leader who can't move money can't be accused of having moved it. If the pastor is a signatory, make sure a second, unrelated signature is always required.
What if our account was opened years ago under an old name or a missing resolution?
Fix it at the next board meeting. Pass a current banking resolution, update the signatories, and take a certified copy of the articles to the branch. It's a one-visit correction once the minutes exist.
The practical wrap
Bring five documents, meaning articles, EIN notice, bylaws, resolution and ID, and the appointment is short. Miss the resolution and it's two appointments.
Then spend ten more minutes on the controls: two unrelated signatories, dual authorization, statements to someone who signs nothing. That's the part that still matters in year five.
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Walk in with the resolution already signed. Organizational Minutes & First-Meeting Resolutions is the fillable first board-meeting packet: bylaws adoption, officers, banking authority and signatories, in the form a bank expects to see. $39, instant download. The rest of the formation sequence is on the start a church hub.
*Faith Docs provides self-help document templates, not legal advice. We are not a law firm. For representation, consult a licensed attorney.*
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