ITIN-Only LLC Banking: Which US Banks Accept You Without an SSN

How this guide differs from the ITIN application guide

This guide is about the next step after the ITIN is in hand. The application itself, including Form W-7, the Certifying Acceptance Agent path, and the seven-to-fourteen-week processing window, is covered in the ITIN for non-resident LLC owners guide. A founder who has not yet applied for the ITIN should read that guide first.

The general business bank account address rules and the bank-by-bank field mapping are covered in business bank account address requirements. A foreign owner whose primary obstacle is a residential address rather than the ITIN should start there.

Recovery from a specific Stripe or Mercury KYC rejection is covered in Stripe Mercury KYC rejection address recovery. A founder who was already rejected should read that recovery sequence in addition to this guide.

Why banks ask about ITIN before SSN

The Bank Secrecy Act of 1970, as amended, requires every US financial institution to verify the identity of each beneficial owner and to keep that record on file. The implementing regulation is 31 CFR §1020.220, which is the customer identification program rule under FinCEN. The rule does not require a specific tax identification number; it requires a verified identity. A passport plus an ITIN can satisfy the rule when the bank's internal policy accepts that combination.

Whether a bank accepts that combination is a business decision. Most fintech-backed business banks built their KYC platform around foreign founders and accept ITIN plus passport plus EIN. Most large retail branch banks built their KYC platform around SSN-holders and treat ITIN-only applicants as exceptions that require additional review. Neither is a legal failure of the ITIN; it is a difference in how the bank scaled its identity program.

The four-document checklist every ITIN-only application needs

Every US business bank account application from an ITIN-only foreign owner needs four documents, in addition to the LLC formation documents. A missing or weak document on any one of these four rows usually ends the application before the bank reads the other three.

The CP565 letter is the document most often lost. The IRS does not automatically reissue CP565, but a reissued letter (often labeled CP565A) can be requested by calling the IRS ITIN Unit. While waiting on the IRS, a recent US tax return that shows the ITIN works as evidence, since the bank's KYC will accept that as proof the ITIN is active.

The EIN letter is the second most common gap. A new LLC that opened the EIN application by fax under the no-SSN process (covered in the EIN without SSN guide) receives the CP575 once. If the letter is lost, the IRS issues a Form 147C as a replacement on request. Most banks accept either CP575 or 147C as the EIN confirmation document.

What Mercury asks for during ITIN-only onboarding

Mercury was one of the first US business banks to publish a foreign-founder onboarding flow that accepts ITIN-only applicants in writing. The application is online, with a guided form that requests the LLC's EIN, the owner's ITIN or passport number, the principal business address, and an upload of the formation documents. Mercury's KYC partner runs the identity verification, and a manual review is triggered when any of the four documents above fail an automated check.

• LLC formation documents. Articles of Organization or Certificate of Formation, plus the Operating Agreement when the LLC is multi-member. Mercury wants a clean copy of the state-stamped filing, not the customer copy without the state seal.
• EIN confirmation. Mercury accepts CP575 or 147C. The LLC name on the EIN letter must match the name on the formation documents, character-for-character.
• ITIN and passport. The ITIN goes on the owner's profile. The passport is uploaded as the identity document. Mercury's verification partner checks the passport against the owner's country of residence and the name on the ITIN.
• Principal business address. Mercury verifies the address against USPS records. A residential address, a PO Box, or an address that the bank flags as a virtual mailbox without commercial classification fails the automated check and routes to manual review.
• Beneficial owner statement. Mercury asks each beneficial owner (any individual with 25% or more ownership) to confirm their tax residency, US tax obligations, and source of funds. The disclosure aligns with FinCEN's Beneficial Ownership Information rule under the Corporate Transparency Act.

Mercury's published policy supports founders from many countries, but the list of supported and unsupported countries changes. A founder in a country recently added to the OFAC sanctions list, or in a country Mercury has temporarily paused, sees a different result. The current supported-country list is on Mercury's onboarding pages, and a founder should confirm before starting the application.

How Relay and Bluevine compare to Mercury for ITIN-only applicants

Relay and Bluevine both offer business banking to LLCs and both have processes that have accommodated ITIN-only foreign owners. The acceptance is conditional and not as broadly published as Mercury's, and the experience differs from Mercury in how the manual review is handled.

A founder who has been rejected by one of these banks should not assume the other two will reject as well. Each bank uses a different KYC vendor and a different internal risk model. A rejection at Bluevine does not predict the outcome at Mercury, and a rejection at Mercury does not predict the outcome at Relay.

Why Chase, Wells Fargo, and Bank of America are difficult

The large retail branch banks are not a single decision. Chase, Wells Fargo, and Bank of America each have national policies, but the application is processed by a local branch, and the branch's experience with ITIN-only LLC owners varies. A branch in a metropolitan area with a large international population is more likely to handle the application without escalation, and a branch in a region with few foreign founders is more likely to ask for an SSN before completing the application.

• Chase opens business checking for LLCs in person at a branch. ITIN-only applicants are typically possible but not guaranteed; the deciding factor is whether the branch banker is trained on the foreign-owner exception or refers it to a manager who is.
• Wells Fargo opens business banking through a relationship banker. ITIN-only applicants are similarly case-by-case; the application sometimes routes to a back-office team that reviews foreign-owner documents.
• Bank of America opens business banking in person; ITIN-only acceptance is documented internally but inconsistently applied at branches without recent foreign-owner volume.

The ITIN expiration trap and how banks read it

An ITIN that is not used on a federal tax return for three consecutive years expires. The IRS published the rule in Notice 2016-48 and updated the expiration mechanism over the years. An expired ITIN does not legally invalidate the past tax filings, but it does fail the bank's KYC verification because the bank's data provider returns the ITIN as inactive.

Renewal is by filing Form W-7 with the renewal box checked, plus a certified passport copy. The renewal does not require a new tax return for the renewal year, but it requires a current passport. The IRS commonly cites about seven weeks of processing time, with longer windows during the tax-season peak. A bank application that depends on a renewed ITIN should wait until the renewal letter arrives.

How a virtual office fills every banking address slot

The address is the variable foreign founders most often underestimate. The ITIN, the passport, and the EIN are objective documents that either exist or do not. The address is a choice the founder makes, and the choice determines whether the bank's automated KYC clears or routes to manual review. A residential address fails for many banks because residential properties do not match the bank's commercial business profile expectation. A PO Box fails because most US banks require a physical address. A free virtual mailbox often fails because the address flags as a Commercial Mail Receiving Agency in the bank's address-classification database.

A save office address is a real commercial street address with mail handling that meets the bank's verification rule. The same address works on the Articles of Organization, the EIN application, the Mercury or Relay onboarding form, and the bank's annual KYC refresh. Consistency across the four documents is what the bank's risk model looks for. The address is also runnable through the free Address Checker before the application, so the founder can confirm USPS Delivery Point Validation in advance.

• Delaware (Wilmington). Bank-accepted commercial address for LLCs formed in Delaware that operate remotely, including foreign-owned LLCs that file Form 5472.
• California (Los Angeles or San Francisco). Useful for foreign founders building toward fundraising or platform partnerships in the West Coast tech corridor.
• New York (Manhattan). Aligned with Mercury and other fintechs' New York presence; useful when the LLC's billing or investor entity is also New York.
• Florida (Tampa). Useful for founders running e-commerce or import-export with a Florida nexus.
• Texas, Washington DC, Wyoming. Each city pairs with a specific operating need; Wyoming for asset-protection structures, DC for federal-facing entities, Texas for owner relocation timelines.

Checklist: documents and confirmations before you apply

1. 1ITIN assignment letter (CP565) in hand, or a recent US tax return that shows the ITIN as evidence of active status.
2. 2Confirmation the ITIN is not expired under the IRS three-year inactivity rule. If unclear, file Form W-7 with the renewal box before applying to the bank.
3. 3Passport that does not expire within six months of the application date. Most banks reject passports nearing expiration.
4. 4EIN confirmation document, CP575 or 147C, with the LLC name matching the state filing exactly.
5. 5Articles of Organization or Certificate of Formation with the state seal, plus the Operating Agreement for multi-member LLCs.
6. 6Real US business address that has been checked through Delivery Point Validation. Run the address through the Address Checker first.
7. 7Beneficial owner information ready: tax residency, ownership percentage, source of funds.
8. 8Choice of bank confirmed against the current acceptance posture for ITIN-only applicants. Mercury, Relay, and Bluevine are the most common starting points.
9. 9Backup plan if the first bank declines. A second application at a different fintech bank is faster than escalating with the first bank.

When the seven items above are ready, open the save office onboarding to set up the address, then apply to the chosen bank. The same address slot fills the LLC formation, the EIN reissue if needed, the bank application, and the annual KYC refresh, which keeps the LLC's identity record consistent across IRS, state, and bank systems.