> ## 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.

# Step 7: Open bank accounts

> Open the PC operating account that payer money lands in and the MSO operating account that runs the business, and understand why the split matters for CPOM.

Your professional entity needs its own bank account that **the PC controls**, because payer money must land there. Your MSO needs its own. They must never be the same account, and the PC's account must not be one the MSO can unilaterally sweep. This is a compliance requirement dressed up as a banking task.

## What Meridian did

Alex opened two accounts: **Meridian Dermatology (Priya Shah, M.D., P.C.), Operating**, with Dr. Shah as the sole signer and Alex holding view-only access, and **Meridian Health Partners, LLC, Operating**, with Alex as signer. Each application took about ten days because both entities were newly formed.

## Why the PC account is a compliance artifact

Three separate rules converge on this account:

1. **CPOM.** The PC earns the professional fees. If payer revenue lands in an MSO account, you have handed a regulator the argument that the lay entity is collecting for the practice of medicine. Control of the receipts is one of the indicia regulators examine.
2. **Payer contracts and Medicare rules.** Payers pay the entity they contracted with, at the Tax ID they enrolled. Medicare's reassignment and payment rules require payment to be made to the provider or supplier, which constrains how receivables can be assigned or directed, a constraint that also shapes how lenders structure facilities against healthcare AR. See [Working capital and lending against healthcare AR](/concepts/finance/working-capital-and-ar-lending).
3. **Basic corporate separateness.** Commingled funds are the fastest route to both veil-piercing arguments and a diligence finding that reprices your company.

<Warning>
  **Do not enroll payer EFT to the MSO's account.** It happens more often than you'd think, usually because whoever filled in the EFT form used the "company" account. Unwinding it means re-enrolling EFT with every affected payer, which takes weeks per payer.
</Warning>

## The minimum account map

For a single-PC launch, open these:

| Entity | Account                      | Purpose                                                                                         |
| ------ | ---------------------------- | ----------------------------------------------------------------------------------------------- |
| PC     | Operating                    | Payer EFTs and patient payments land here; clinical payroll and the management fee are paid out |
| MSO    | Operating                    | Management fee income; all non-clinical expenses                                                |
| MSO    | Payroll (optional at launch) | Segregates the non-clinical payroll draw                                                        |
| MSO    | Tax reserve (optional)       | Set aside estimated taxes so they aren't spent                                                  |

As you grow, this expands considerably: per-PC accounts, refund clearing accounts, per-location structures. See [Structure accounts across your entities](/guides/banking/structure-accounts-across-entities) and [Account structures for MSO-PC groups](/concepts/banking/account-structures).

## What the bank will ask for

Newly formed professional entities are a harder KYB case than a normal LLC, because the bank has to verify both the entity and the license behind it. Assemble this before you apply:

**For the PC:**

* Filed articles of incorporation, state-stamped
* EIN confirmation letter (CP 575)
* Bylaws and the organizational consent authorizing accounts and naming signers
* Stock certificate or ownership schedule showing the licensed shareholder
* The clinician's professional license
* Government ID for every signer and beneficial owner
* DBA/assumed name certificate if you operate under a brand

**For the MSO:**

* Certificate of formation and operating agreement
* EIN confirmation letter
* Beneficial ownership information for owners at or above the bank's threshold
* Foreign qualification certificate in the operating state

Some banks also ask to see the MSA. That is a reasonable request: it explains the relationship between two accounts owned by different people. But read what you hand over.

See [KYB/KYC document checklist](/reference/banking/kyb-document-checklist) for the full per-entity packet.

<Tip>
  **Beneficial ownership questionnaires do not understand this structure.** Standard forms ask "who owns 25% or more of the entity?" 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 is how you end up with an inaccurate filing.
</Tip>

## Who signs

The PC's signer must be the PC's officer, in practice, the clinician-owner. This is the part founders find uncomfortable: the person controlling the account holding all the revenue is not the person running the business.

Handle it with structure rather than by cheating:

* The clinician-owner is the **signer** on the PC account.
* Operations staff get **view-only** access for reconciliation.
* The **MSA** authorizes the MSO to provide billing and financial administration services, including preparing payments for approval.
* The monthly management fee moves on an **invoice**, not a standing sweep the MSO controls unilaterally.

An MSO with unilateral withdrawal authority over the PC's operating account is a CPOM self-audit finding. See [Move money between PC and MSO](/guides/banking/move-money-mso-pc).

## In-person vs online

Professional entities often trip online-only account opening flows: the automated KYB can't verify a two-week-old PC with a licensed owner and a d/b/a. Expect either a manual review or a branch visit. Budget one to three weeks per entity, and start this in parallel with Step 6 rather than after it.

There is also a genuine structural problem waiting for you at scale: a generalist bank gives you one login per legal entity. At one PC that's an annoyance. At ten it is a real operational burden: dozens of logins, per-entity statements, and no cross-entity view. [Open bank accounts for your MSO and PCs](/guides/banking/open-bank-accounts) covers that problem and the options, including healthcare-focused platforms built around it.

## Your artifact from this step

* PC operating account, open, with the clinician as signer
* MSO operating account, open
* Account and routing numbers recorded for Step 8's EFT enrollments
* View-only access provisioned for bookkeeping
* A written note of which account each payer's EFT will target

## Checklist

* [ ] PC operating account open, signer is the PC's licensed officer
* [ ] MSO operating account open
* [ ] No shared account between the entities
* [ ] Bookkeeper has read-only access to both
* [ ] Beneficial ownership questionnaires answered accurately
* [ ] Account numbers documented for payer EFT enrollment
* [ ] Confirmed no standing MSO sweep authority over the PC account

## Next

<Card title="Step 8: Enroll with your first payer" icon="arrow-right" href="/start/zero-to-paid/enroll-with-your-first-payer">
  Pick one payer and go end to end: contract, EDI, ERA, EFT.
</Card>


## Related topics

- [Open bank accounts for your MSO and PCs](/guides/banking/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)