> ## Documentation Index
> Fetch the complete documentation index at: https://mso.getlemma.com/llms.txt
> Use this file to discover all available pages before exploring further.

# Open bank accounts for your MSO and PCs

> What accounts you need, why payer money must land in PC-controlled accounts, the KYB documents banks demand, and the multi-entity problem generalist banks don't solve.

Opening accounts for an MSO-PC group is a compliance task disguised as an administrative one. **Payer money must land in an account the PC controls**, the entities must never share an account, and the MSO must not hold unilateral withdrawal authority over the PC's receipts.

## Prerequisites

Per entity:

* Filed formation documents, state-stamped
* EIN confirmation letter (CP 575)
* Bylaws or operating agreement, plus the consent authorizing accounts and naming signers
* Ownership documentation
* The clinician's professional license (PC)
* Government ID for every signer and beneficial owner
* DBA certificate if operating under a brand

Full list: [KYB/KYC document checklist](/reference/banking/kyb-document-checklist).

## What accounts you need

| Entity      | Account               | Purpose                                                                         | Needed at launch? |
| ----------- | --------------------- | ------------------------------------------------------------------------------- | ----------------- |
| **Each PC** | Operating             | Payer EFTs and patient payments in; clinical payroll and the management fee out | **Yes**           |
| Each PC     | Payroll               | Segregates clinical payroll                                                     | Later             |
| Each PC     | Refund / disbursement | Controlled account for patient refunds                                          | Later             |
| **MSO**     | Operating             | Fee income; all non-clinical expenses                                           | **Yes**           |
| MSO         | Payroll               | Funded before each run                                                          | Soon              |
| MSO         | Tax reserve           | So estimated taxes aren't spent                                                 | Soon              |
| MSO         | Reserve               | Runway, and a cushion against events like a clearinghouse outage                | Soon              |

Start with two. Add the rest as they solve a specific problem. See [Account structures](/concepts/banking/account-structures).

## The rules that aren't negotiable

**1. Payer money lands in the PC's account.** Three separate rules converge here: CPOM (the PC earns the professional fee, and control of receipts is an indicium regulators examine), payer contracts and Medicare payment rules (payment goes to the enrolled entity), and basic corporate separateness.

**2. Never a shared account between the entities.** Ever.

**3. The PC's signer is the PC's licensed officer**, in practice, the clinician-owner.

**4. No standing MSO sweep authority over the PC's account.** The money movement may be entirely legitimate; the *control* is the finding. The management fee moves on an **invoice**, not an automated pull. See [Move money between PC and MSO](/guides/banking/move-money-mso-pc).

## Steps

<Steps>
  <Step title="Assemble the document packet per entity">
    Newly formed professional entities are a harder KYB case than a normal LLC, because the bank must verify both the entity and the license behind it. Expect manual review or a branch visit, and budget 1–3 weeks per entity.
  </Step>

  <Step title="Answer beneficial ownership questions accurately">
    **Standard forms do not understand this structure.** "Who owns 25% or more?" — for the PC, the honest answer is the clinician, 100%, even though the economics are governed by the MSA.

    Answer accurately and be prepared to explain. Guessing at what the bank wants to hear produces an inaccurate filing.
  </Step>

  <Step title="Set signers and access deliberately">
    * **Signer on the PC's accounts:** the PC's licensed officer
    * **Read-only:** bookkeeper, controller, and whoever reconciles
    * **Initiator, where supported:** operations may prepare payments for the officer's approval
    * **Never:** an MSO executive as signer on a PC account
  </Step>

  <Step title="Apply the naming convention">
    Decide once: `[Brand] [State] PC, Operating`. Consistent naming is what makes a thirty-account list readable and reconciliation scriptable.
  </Step>

  <Step title="Record the account details for payer EFT enrollment">
    Routing and account number per PC, ready for [EDI/ERA/EFT enrollment](/guides/enrollment/set-up-edi-era-eft).
  </Step>

  <Step title="Confirm the bank surfaces ACH addenda data">
    The health care EFT standard carries the **TRN reassociation trace number** in the ACH addenda record — that is how you match a deposit to its 835. Many banks don't display addenda in standard reporting, which forces manual matching. Ask before you choose.
  </Step>
</Steps>

## The problem that arrives at scale

Being direct about it, because it is the honest state of the market.

**Generalist banks give you one login per legal entity.** That is the product working as designed — to a bank, your eleven entities have no relationship to each other. At one PC it is an annoyance. At ten it means:

* **Eleven logins** with separate credentials, and eleven statement downloads a month
* **No cross-entity view**, answering "how much cash do we have?" means logging into everything and building a spreadsheet
* **Manual intercompany movement**, ten fee transfers a month, each invoiced and reconciled separately
* **Repeated KYB onboarding**, every new PC is a fresh packet at the same friction as the first
* **Per-entity check stock and signers** for patient refunds

And a second, deeper problem: **no generalist bank does healthcare compliance out of the box.** None of them know what CPOM-clean money movement is, why the PC's account must not be sweepable by the MSO, why a management fee transfer differs from an owner draw, or how to reassociate a deposit to an 835. That logic lives entirely in your head and your bookkeeper's.

<Info>
  **Lemma** is a healthcare-focused banking experience built for exactly this shape of problem, one interface across every PC and the MSO, designed around MSO-PC compliance patterns rather than adapted to them. Named here as the designated disclosure page under our [mention policy](/reference/appendix/about-lemma).

  Everything else on this page applies regardless of where you bank, and the account structure, signer, and reconciliation discipline described here works at any institution.
</Info>

## Verify it worked

* [ ] One operating account per PC, one for the MSO, no shared accounts
* [ ] PC signer is the PC's licensed officer
* [ ] No MSO withdrawal authority over PC accounts
* [ ] Read-only access provisioned for bookkeeping
* [ ] Beneficial ownership answered accurately
* [ ] Naming convention applied
* [ ] Account details recorded for EFT enrollment
* [ ] ACH addenda availability confirmed
* [ ] Per-entity setup runbook written for the next entity

## Common failure modes

| Failure                                      | Consequence                              |
| -------------------------------------------- | ---------------------------------------- |
| Payer EFT enrolled to the MSO's account      | CPOM problem plus weeks of re-enrollment |
| One account for both entities                | Commingling                              |
| MSO executive as signer on a PC account      | Control finding in a CPOM audit          |
| Standing ACH debit authorization for the MSO | Same                                     |
| Beneficial ownership guessed at              | Inaccurate filing                        |
| No naming convention                         | An unreadable account list at scale      |
| Bank doesn't surface ACH addenda             | Manual TRN matching forever              |


## Related topics

- [Step 7: Open bank accounts](/start/zero-to-paid/open-bank-accounts.md)
- [Structure accounts across your entities](/guides/banking/structure-accounts-across-entities.md)
- [Move money between PC and MSO (the right way)](/guides/banking/move-money-mso-pc.md)
- [Why MSO-PC banking is different](/concepts/banking/why-healthcare-banking-is-different.md)
- [Account structures for MSO-PC groups](/concepts/banking/account-structures.md)
- [KYB/KYC document checklist for account opening](/reference/banking/kyb-document-checklist.md)
- [Per-entity account & access checklist](/reference/banking/per-entity-account-checklist.md)