Bank Logo on Information Statements Mailed to Bank Customers

Issue

Use of Bank Logo on Information Reporting Statements Mailed To Bank Customers.

Position Statement

The Internal Revenue Service intends to prohibit the inclusion of payer's logo, slogan, or advertising on substitute forms used for reporting certain reportable payments to recipients.

Explanation

This prohibition (contained in Rev. Proc. 2008-36) will create unnecessary confusion for the taxpayers who receive these forms, and also cause both administrative and financial disruptions to the operations of businesses that use these substitute forms for reporting payments.

More than 10 years ago, the IRS started permitting payers using substitute forms for reporting payments to include slogans, some advertising, or logos on the forms in order to help their customers or clients to identify the sender and thus identify the document as an important tax return preparation document.  As a result of this sanction from the Service, many payers (including financial institutions) have invested a lot of time, effort, and financial resources in developing substitute forms that contain their logos or slogans and provide useful information to the taxpayers receiving these forms.  In fact, for some banks their name (presented in special graphics) is their logo.

The ABA objects to a complete ban on the use of logos and slogans.  We suggest that the Service permit the inclusion of slogans or logos (e.g., name graphics and or the institution's picture logo) as identifiers for the taxpayers and set specifications as to the type and location of such logos or slogans on the forms.  We believe that the use of logos on information returns is important for both the taxpayer receiving the form and the entity that issues it.  Such logos help taxpayers more readily identify the sender and the accounts and payments to which the document relates.

Contact for further information: Fran Mordi (202) 663-5317