What existence means, and why the W-9 alone does not prove it
A W-9 is a certification by the payee. It says what name and TIN the payee wants on its 1099 and that the TIN is correct, under penalties of perjury. It is not evidence that the entity on line 1 is registered anywhere, that the TIN belongs to that name, or that the person who signed it is who they say they are. Each of those is checked against a different public record, and none of the records checks the others. The state register does not know the TIN; the IRS does not know whether the entity was dissolved last year; the OIG and OFAC lists do not know whether the entity exists at all. Existence, in the sense a payer needs, is the four records agreeing.
The six steps
- Collect the W-9 and read line 1. The name on line 1 must be the name the IRS associates with the TIN: the individual's name for an SSN or a disregarded LLC, the entity's name for an EIN. The W-9 walkthrough and the LLC and sole proprietor cases cover the five patterns that produce most mismatches. Ask for the state of formation and the state entity number on the request; the vendor onboarding checklist has the fields.
- Match the name and TIN against IRS records. The IRS TIN Matching program returns a code that says whether the pair the payee gave is one the IRS recognises; it does not return a name. A mismatch at this stage is a W-9 problem, not a fraud finding, and the fix is to resolicit with the name on the payee's IRS notice or Letter 147C. TIN Comply runs this match at signup and keeps the dated result.
- Confirm the entity in its formation state's register. Use the business entity search directory to reach the right system. Confirm three things: an entity with the W-9 name exists, its status is active or in good standing, and the entity number the vendor gave matches. Save the record with the date. Where the register shows officers or managers, note them; they are the people a later bank-change request should come from. A sole proprietor is not in the register; for an individual payee the TIN match, an ID where your policy requires one, and a licence lookup where the trade is licensed stand in for it.
- Screen the name, the owners and the officers against sanctions lists. OFAC's SDN and consolidated lists apply to every payee in every industry; SAM.gov applies to anyone paid with federal money. Vendor sanctions screening sets out the list set and the clearing of false positives, and the 50 percent rule explains why the owners matter. TIN Comply's sanctions screening covers these lists on the same record as the TIN match.
- For healthcare payees, add the exclusion checks. LEIE and SAM.gov for everyone, then the state Medicaid list for the enrollment state and every state served, with the SSN or EIN confirmation on a name hit; the Medicaid exclusion list directory records what each state publishes and which lists are terminations rather than exclusions. Where the payee bills Medicare, confirm enrollment; TIN Comply's Medicare enrollment check does that lookup.
- For motor carriers, add the FMCSA checks. USDOT number and operating status on SAFER, authority and insurance on L&I, safety rating and out-of-service, UCR for the current year, and the name match across the W-9, FMCSA and the insurance certificate. The carrier verification page explains each record and what a bad result means; TIN Comply's carrier validation runs the FMCSA checks from the same sources.
Order matters. The register check is cheap and catches a dissolved or misnamed entity before you spend time on a TIN mismatch that the register already explains. The sanctions screen comes after the name is settled, because screening the wrong name clears the wrong party.
What to keep
For each check: the source, the search key used, the result, and the date, in the vendor file with the W-9. A screenshot or saved PDF of the register record and the LEIE confirmation page is enough. The TIN match log is the record a Notice 972CG response turns on, and the dated register and screening records are what a bank-change fraud review or an OIG inquiry asks for first. The one-page checklist is laid out as that file.
When to repeat the checks
- Register: at onboarding; on any name, address or bank change; before a payment after a year's gap. Administrative dissolution for an unfiled annual report is the common silent change.
- TIN match: at onboarding and on any name or TIN change; after a CP2100 listing, as part of the solicitation sequence.
- Sanctions and exclusions: monthly for active payees. The OIG posts LEIE updates by the 10th of each month, most states that state a cadence say monthly, and OFAC changes without a schedule.
- Carrier authority and insurance: before each load for a new carrier, then on the insurance cancellation date and the authority history; the FMCSA bulk files and the QCMobile API make a nightly refresh practical.
Questions people ask
The register says active but the address on the W-9 is different. Problem?
Not by itself. The register holds the principal office and registered agent addresses; the W-9 holds the address for the 1099. A different remittance address, especially one that changed by email, is the signal to call a known number before paying.
Do I need a certificate of good standing?
No. The free search result, saved with the date, is the same evidence for your file. A certificate matters when a third party will rely on it. The directory shows the fee where the state publishes one; it is free in Colorado and Wyoming and under $50 almost everywhere else.
The vendor is foreign and has no state registration. What replaces the register?
The W-8 series replaces the W-9, and the formation record comes from the home country's register or the documents the vendor supplies; the foreign vendor guide covers the documentation and withholding. Sanctions screening applies with more force, not less.
Is any of this required by the IRS?
The IRS requires a correct name and TIN on the information return and gives a penalty waiver for a payer that solicited properly; TIN matching is voluntary and the register check is not an IRS rule at all. The register, sanctions and exclusion checks come from fraud control, OFAC regulations and the federal health care program rules. They share a file because they share a payee.