Who gets a disc
| Error records on the notice | What arrives |
|---|---|
| Fewer than 50 | CP2100A with a paper listing |
| 50 to 249 | CP2100 with a paper listing |
| 250 or more | CP2100 with an encrypted CD or DVD |
| Notice 972CG, fewer than 250 returns | Paper listing |
| Notice 972CG, 250 or more | Encrypted CD or DVD |
The thresholds are in IRM 3.42.9.13. The disc is encrypted, and the help desk (Technical Services Operation) releases the encryption code only to a contact who has a PIN on file from Form 10301, CD Encryption Code Authorization for CP2100/972CG Notices.
How the form works
Form 10301 does two things: it names the people at your company who are allowed to receive the encryption code, and it records a PIN those people choose. The PIN is 10 alphanumeric characters with no special characters, self-assigned by you (IRM 3.42.9.15). When a disc arrives, one of the named contacts calls the help desk, gives the PIN, and receives the 10-character uppercase-letter encryption code that opens the disc. The PIN stays on file: "There is no need to reapply yearly" (IRM 3.42.9.15.1).
One PIN can cover several entities that file under the same EIN. A subsidiary with its own EIN needs its own Form 10301 (IRM 3.42.9.15.1).
Step by step
- Decide who. The contacts on the form should be the people who will actually run the B-Notice process in October, not the officer who signed the TCC application. Include a backup.
- Choose the PIN. Ten characters, letters and digits only. Store it where the contacts can find it in a year; it is the only key.
- Complete and fax the form to the help desk at the number on the current form. The IRM's estimate for processing a faxed form is about five days (IRM 3.42.9.15).
- Repeat for each EIN that files information returns and could reach 250 error records.
- When the disc arrives, a named contact calls the help desk at 866-455-7438, gives the PIN, and receives the encryption code. Open the disc, load the listing, and start the CP2100 process.
- When contacts change, file a new Form 10301. The IRS will not read a code to someone who is not on the form.
File the form in August. The fall CP2100 mailing starts in September, and the 15-business-day clock for B-Notices runs from the notice date whether or not you can open the disc.
Timing against the B-Notice clock
Publication 1281 gives you 15 business days from the CP2100 date, or the date you received it, whichever is later, to mail B-Notices, and requires backup withholding to begin no later than 30 business days after the notice date for payees who do not respond. A faxed Form 10301 takes about five days to process. A payer that receives a disc with no PIN on file, faxes the form, waits for processing, then calls for the code has used a third of the window before reading the first name. The deadline calculator turns the notice date into the two dates.
When something goes wrong
- The disc is damaged or missing. Notices are retained for ten years and can be recreated, but recreate requests are not processed in the two weeks after a mailing date unless the listing was missing or the disc damaged (IRM 3.42.9.13.4). Say which.
- The disc went to the wrong company. The IRS asks for it back by UPS on the IRS account (IRM 3.42.9.15.1). Do not open it.
- You do not know who filed the returns. A payer is entitled to the business name behind the TCC on its notice, even if a third party transmitted (IRM 3.42.9.13.5). Ask the help desk; a callback takes about three business days.
- The notice went to an old address. An undeliverable CP2100 keeps its original date when re-mailed; only a 972CG gets a fresh 45-day clock (IRM 3.42.9.18.5). Keep Form 8822-B current.
- A representative needs the code. Third parties need a Form 2848 or 8821 on file with the help desk (IRM 3.42.9.13.4).
Questions people ask
We are under 250 now. Should we still file it?
If the vendor base is growing or a system change is coming, yes. The form costs nothing, does not expire, and the alternative is losing a week in October. It also covers the 972CG disc, whose threshold is the same.
Can our filing vendor receive the code for us?
Only with a Form 2848 or 8821 on file. The simpler path is to name the vendor's contact on your own Form 10301 alongside your staff.
Does the PIN change every year?
No. It stays until you file a new form. Change it when a named contact leaves.