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Topic: Federal Identification Number (Tax ID)

Question by: Rebecca Longfellow

Jurisdiction: Indiana

Date: June 22, 2015

|Jurisdiction |Question(s) |

| |I am wondering if there are any SOS offices or business registries that capture the Federal Tax ID number (FEIN) or Non U.S. equivalent during: |

| | |

| |1. Formation |

| |2. Business Entity Report |

| |3. At any other time |

| |4. Does another state agency share the FEIN with your office |

| | |

| |If the FEIN number is requested or shared, do you store the number as part of the business record in your database? |

|Manitoba | |

|Corporations Canada | |

|Alabama | |

|Alaska | |

|Arizona | |

|Arkansas | |

|California |Federal Tax ID numbers are not required for any business document filed within the California Secretary of State's office. If presented on a document, staff will redact |

| |the tax ID prior to filing in our efforts to protect personal and business identity information. |

|Colorado | |

|Connecticut |We neither capture nor require FEIN# in CT. While I am not 100% sure, I think I heard somewhere that FEIN# is now considered protected taxpayer info, so that perhaps |

| |nobody should be requiring that data set. As a ministerial agency, we would file a voluntary FEIN# disclosure on one of our forms as-is, without redaction. |

|Delaware | |

|District of Columbia |In DC we do not capture or require FEIN. |

|Florida |Florida law requires it be reported to us on the annual report. We store it and it is on our website. |

|Georgia | |

|Hawaii |Hawaii does not capture the Federal Tax ID number (FEIN). |

|Idaho | |

|Illinois | |

|Indiana | |

|Iowa | |

|Kansas |We ask for the FEIN on the annual report form but it is not required by law so it is optional. We store it in the database if it comes in electronically, but we don’t |

| |data enter the information from paper. |

| | |

| |We have considered requiring by law because it seems to be the best vehicle to link different state agencies. |

|Kentucky | |

|Louisiana |Prior to June 7th of this year we did not collect the FEIN. As of that date our GeauxBIZ portal launched and we now collect the information. However we are collecting it |

| |on behalf of the La. Dept. of Revenue and Taxation only. We do not store the information. |

|Maine | |

|Maryland | |

|Massachusetts |As of January 1, 2015, this office no longer accepts FEINs on any new formation or registration document. Entities making filings with this office may not include their |

| |FEIN as part of the filing if it is not their current ID number with our office. Prior to that time, we would capture the FEIN on the filings if the filer included it in |

| |their filing. Additionally, we would update the ID number if the filer wished to have their number be the same as their FEIN. At this time there are still some entities |

| |that instead of a nine digit state assigned identification number use their FEIN. However, many have begun to request that a state ID number be assigned and the FEIN |

| |redacted from our system. |

|Michigan | |

|Minnesota |Minnesota does not request nor do we store FEIN information in our business records. |

|Mississippi | |

|Missouri |Missouri does not require or accept the FEIN on any documents filed with our office and the other state agencies do not share that information with us. |

|Montana |In Montana we do not require an FEIN number when registering any type of business entity. |

|Nebraska | |

|Nevada | |

|New Hampshire | |

|New Jersey | |

|New Mexico | |

|New York | |

|North Carolina |North Carolina does not capture this number at present. There was legislation introduced this session which will allow the SOS to capture this number for sole |

| |proprietorships and/or general partnerships if they have one. |

|North Dakota | |

|Ohio |Ohio has a statute that states we must reject a filing or redact it if it contains a federal tax id number or social security number, therefore, we do not capture or |

| |store this information. |

|Oklahoma | |

|Oregon | |

|Pennsylvania | |

|Rhode Island | |

|South Carolina | |

|South Dakota | |

|Tennessee |In Tennessee, the SOS does not request and we don't want FEIN information on filings tendered to the Business Services Division. No agency shares FEIN information with |

| |us. |

|Texas | |

|Utah |Utah's OneStop collects it on behalf of the Tax Commission but we never see it or store it. It goes straight to their download. |

|Vermont | |

|Virginia |We do not require a FEIN for business entities on any filings. We also do not consider it personal identifiable information, as our redaction statute only applies to |

| |individuals. So if it is included in a document, it will become a part of the public record to the extent that someone can request a copy of the filing. |

|Washington | In Washington State we do not require or capture the FEIN for entity filings. |

|West Virginia | |

|Wisconsin | |

|Wyoming | |

Additional comments:

Full text of email:

All,

I am wondering if there are any SOS offices or business registries that capture the Federal Tax ID number (FEIN) or Non U.S. equivalent during:

1. Formation

2. Business Entity Report

3. At any other time

4. Does another state agency share the FEIN with your office

If the FEIN number is requested or shared, do you store the number as part of the business record in your database?

I have a feeling I know what the majority of you will answer, but I am interested in hearing from you. Thank you in advance for your help.

Rebecca Longfellow

Director of Business Services Division

Indiana Secretary of State Connie Lawson

302 W. Washington Street Rm. E-018

Indianapolis, IN 46204

rlongfellow@sos.

317.232.6583

Follow us on Twitter: @SecretaryLawson

Like us on Facebook: Secretary of State Connie Lawson

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