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Every route to an account collects the same underlying facts because the requirement is regulatory: a bank must identify and verify each beneficial owner at or above 25% and one control person for every legal entity customer (31 CFR 1010.230). The verification method varies by institution. A newly formed professional entity may require extra review because the bank must verify both the entity and the professional license associated with it. This page first lists what Lemma asks for, then the additional documents a brick-and-mortar bank may request. Lemma is named because that difference is the subject of the page. Other platforms that verify entities from registration data may use a similar process, but applicants should confirm each institution’s requirements. See the mention policy. Requirements that apply to either route appear at the end.

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At Lemma

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What you provide

The entity is checked against tax and state registration records, so the application is three groups of fields, identical for the PC and the DSO: In an ordinary application, these fields take about five minutes to complete. Lemma does not initially request formation PDFs, bylaws, a stock ledger, a certificate of good standing, or a branch visit. Government ID is a fallback rather than a default and may be requested when the tax ID does not verify, which is more likely for a recently formed entity.

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Timing

The application takes about five minutes per entity, and most entities are approved within hours. Each additional PC uses the same short form, subject to the verification results for that entity.

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When the MSA is relevant

An account application does not ordinarily require the management services agreement (MSA). A banking platform may still use the agreement to configure authorized funds flows, such as directing patient revenue to the practice and paying management fees against approved invoices. Any access, sweep, or transfer right must also match the entity documents, bank authorizations, and applicable state rules.

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Before you apply

  • The CP 575 legal name recorded exactly as printed, plus the EIN and state of incorporation
  • The control person: for a professional entity, the PC’s licensed officer
  • Every beneficial owner at or above 25%, answered accurately
  • Government ID for each of them, in case the automated check doesn’t clear
  • The executed MSA, if you want the accounts configured against it

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At a brick-and-mortar bank

Everything above, plus the following, per entity.

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For a professional entity (PC / PLLC / PA)

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For the DSO

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Timing

Allow one to three weeks per entity. A recently formed professional entity with a dentist owner and a d/b/a may not pass automated KYB checks, so expect possible manual review or a branch visit. Each additional PC may require a similar document packet and review. Payer EFT enrollment requires the receiving account details. Begin the banking process alongside NPI, credentialing-profile, and payer-enrollment work so the missing account does not delay payment setup.

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How a traditional bank may use the MSA

A brick-and-mortar bank that requests the MSA generally uses it for diligence and retains it in the account file. Unless the account product includes operational controls tied to the agreement, the customer remains responsible for enforcing the agreement’s funds-flow and approval requirements.

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Before you apply

Everything in the Lemma checklist above, plus:
  • The full document packet, current and legible, per entity
  • A one-paragraph written explanation of the DSO-PC structure
  • The list of authorized signers, with the PC’s officer identified
  • One to three weeks of lead time in the launch plan

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Regardless of where you bank

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Beneficial ownership

Every institution will ask about beneficial ownership and control, although its form may not be written with a DSO-PC structure in mind. The form asks: “Who owns 25% or more of the entity?” For a dentist-owned PC, report the licensed equity owner shown in the entity’s actual cap table, even when the shares are subject to transfer restrictions and the PC has an MSA with the DSO. For the DSO, report its actual cap table and any other owners the institution’s current rule or form requires. Answer from the governing documents and current ownership records. Keep a short written explanation of the DSO-PC relationship available for follow-up questions, including why the professional entity and management company have different owners. Also expect questions about control, including who directs the entity’s activities and who may act on its accounts. Answer according to the governing documents, bank resolutions, and actual authority. If those answers conflict with the intended clinical-control boundary, include the issue in the CPOD self-audit.

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The name must match, everywhere

The legal name on the CP 575 must match:
  • The bank account
  • The W-9
  • NPPES
  • Every payer enrollment
  • The claim’s billing provider name
A legal-name mismatch can cause bank or payer enrollment questions and claim rejections. Record the CP 575 name exactly as printed, including punctuation and abbreviations, and reconcile that value across banking, NPPES, W-9s, payer records, and claims. See Get NPIs.

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Other account requirements

  • Read-only access provisioned for whoever does the bookkeeping
  • A naming convention decided once and applied to every account
  • Confirmation the bank surfaces ACH addenda data, since the TRN is how you reconcile 835s to deposits

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The per-entity folder template

Maintain this folder whether or not the bank asks for it. Payer enrollment, malpractice renewal, audits, and diligence rely on many of the same documents, and an organized file can reduce the work required for later entities:
Last modified on August 21, 2026