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hackclub
Compliance around payments via ACH/Check
### Tasks
- [x] Collect invoices/receipts prior to payment
- [x] Collect receipts for all payments including ACHs/Checks
- [ ] https://github.com/hackclub/hcb/issues/5348
- contractor (salary): w9 with invoice. w8-ben
- How does this differ from card charges? We don't require W9 for that
- payment good & services: invoice
- over $600 per calendar year (maybe we should just require it regardless of total sent per year)
- reimbursement: receipt
- grants: we don't need anything
I will setup a meeting with Liv and Bence to chat more about our requirements for this
https://github.com/hackclub/hcb/issues/4831 will handle a portion of this issue. The goal of this issue to provide more thoughts into payment compliance in general
Decisions from meeting with Bence on January 5th:
- We will collect a W-9/W-8 BEN for ALL payments
- Regardless of if it's under $600
- Reimbursements do NOT count in the $600; and thus do not need a W-9
- We need a reliable way to identify a single entity (counter party)
- This is because two orgs may invoice the same person. The total of the two invoices is what we paid that person.
- Email addresses are a great identifier, but it's not 100% reliable. A person may have multiple email addresses.
- We will require invoices/receipts BEFORE payment (except for card)
- This applies to ACHs and Checks
- We need a receipt for EVERY payment
- This includes every recurring payments (e.g. subscriptions)
- This also includes reimbursements
Open Questions
- How do we uniquely identify an individual?
- Probably via their W-9 info (SSN)
- How do we securely store W-9/W8-BEN/SSN?
I'm continuing this conversation with Kris
https://hackclub.slack.com/archives/C04T8NL8TCJ/p1707140614320939