Help! I don’t have that document.

The certification process is co-dependent.

  • The business itself is being certified as being capable to provide its products and/or services.
  • The business is being certified as being at least 51% owned, operated and controlled by a diverse individual(s) who possesses the knowledge and skill to run the business applying for certification.

This is why certifiers require supporting documentation about the diverse owner(s) and the business. It’s also why you’ll see similar supporting documents requested from the various certifiers, whether they’re a 3rd party certifier or a state or federal government certifier.

Some examples of supporting documents requested by all certifiers:

  • Resumes of owners, board of directors/officers, and key management team
  • The business’s federal tax returns, including all related schedules or any requests for extensions, for the past three years
  • Bank authorization/signatory cards
  • Employee list, which includes titles and dates of employment
  • Proof of the owner’s (or owners) diverse status

We’re often asked what to do if you don’t have some of the required documentation. Certain ones, such a business’s organizing documents (i.e. LLC Agreement, Articles of Incorporation, or Partnership Agreement) HAVE TO BE provided. It doesn’t matter if you’re a single member LLC or a family owned business, documents of this nature go back to the certifier’s ability to verify the governance and control of a business. They want to ensure that the diverse owner(s) can make decisions for or about the business without anyone else’s oversight.

In many instances a straightforward statement as to why you cannot provide a piece of requested documentation is acceptable to a certifier. For example a number of 3rd party certifiers ask for the payroll of the month prior to your certification application being submitted. If the business doesn’t have any employees and the owner is not yet taking a salary, a statement to that effect can be submitted in lieu of the payroll report. Or say the owner started the business in 2018, but did not begin paying themselves until 2019 – there would be no W-2 and/or 1099 for the most recent year. Again, a brief written account of the facts should be given to the certifier.

Not all missing documents can be resolved with just an explanation of why it isn’t available. If a business hasn’t filed three years’ worth of taxes, the owner’s (or owners’) personal taxes MUST BE submitted in their place. Example: If you have two years of business taxes, one year of personal taxes are needed. (Note: Most government certifiers usually require three years of both business AND personal taxes. And, if need be, they’ll recognize the personal taxes in lieu of the business taxes.)

A missing bank signature card is another document that requires more than just a statement from the owner. Instead, certifiers look to have a letter from the banking institution – on the bank’s letterhead – that states the company’s name, type of account(s) held, date when the account(s) was opened, who has signature authority on the account(s), and if there are any restrictions on those with signature authority. If you request that the letter include the amount used to open the account(s), it can also be used as one of the owner’s documents to prove initial investment/contribution to acquire ownership in the company.

Remember, if you’re ever in doubt about how to handle supporting documents you don’t have, you can reach out to the certifier. They’ll tell you their policies around their required documentation and what, if anything, they’ll accept in place of what is requested.

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