The IRS changed the W-9 form in Dec. 2014 to add the FATCA information. Do we now need to collect the actual W-9s, or can we continue to just require the tax ID, and if it TIN-matches, we're covered?


It depends on the nature of the payment. If the payment is subject to FATCA reporting, then you should obtain a W-9 as documentation of a new payee’s U.S. status (including corporations).  But for a typical accounts payable payment for services, rent or royalty, you must have a TIN, but you do not have to get it on a W-9.

The exception is if you have received a (first) B-notice (CP2100) on the vendor—in that case you are required to get a W-9.  But if you just have new vendor, and payments that are not FATCA-related, then you only need the TIN.

We do recommend using the IRS TIN match program, which you apparently are doing.

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