- 4.1 What information should I collect about my company, its beneficial owners, and its company applicants?
- 3.2 Who is a company applicant of my company?
Chart 7 – Required information checklists
Reporting Company
» Report all trade names or DBAs.
» Report the address of the principal place of business in United States, or, if the reporting company’s principal place of business is not in the United States, the primary location in the United States where the company conducts business.
» If a foreign reporting company has not been issued a TIN, report a tax identification number issued by a foreign jurisdiction and the name of such jurisdiction.
Each Beneficial Owner and Company Applicant
Not all reporting companies are required to report information about company applicants. See Chapter 3 for assistance in identifying whether your company is required to report company applicant information.
» Report the individual’s residential street address, except for company applicants who form or register a company in the course of their business, such as paralegals. For such individuals, report the business street address. The address is not required to be in the United States
» U.S. passport
» State driver’s license
» Identification document issued by a state, local government, or tribe
» If an individual does not have any of the previous documents, foreign passport
If an individual has obtained a FinCEN identifier and provided it to a reporting company, the reporting company may include such FinCEN identifier in its report instead of the information required about the individual.
The Reporting Rule includes four special reporting rules that may affect your company’s reporting obligations.
1. Owned by exempt entity: You do not need to report information about any beneficial owner whose ownership interests in a reporting company are held through one or more entities, all of which are themselves exempt from the reporting company definition. Refer to Chapter 1.2 for the types of entities that are exempt from the reporting company definition.
- If this special rule applies, then you may report the names of all of the exempt entities instead of information about the individual who is a beneficial owner of your company through ownership interests in those exempt entities.
2. Minor child: You do not need to report information about a beneficial owner of the reporting company who is a minor child, provided you have reported the required information about the minor child’s parent or legal guardian.
- If this special rule applies, you may report the required information about the child’s parent or legal guardian instead of the child.
Note: If you report a parent or legal guardian’s information instead of a minor child’s information, then you must indicate in your BOI report that the information relates to a parent or legal guardian of the minor child.
- If this special rule applies, you must report one individual who exercises substantial control over the company. You do not need to report any company applicants. If more than one individual exercise substantial control over the company, you must report information about the individual who has the greatest authority over the strategic management of the company.
- If this special rule applies, do not report company applicants. Specify on the BOI report that the company was created or registered before January 1, 2024.
A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an individual or reporting company upon request after the individual or reporting company provides certain information to FinCEN.
- An individual or reporting company is not required to obtain a FinCEN identifier.
- An individual or reporting company may only receive one FinCEN identifier.
- Your company may include FinCEN identifiers in its BOI report instead of certain required information about beneficial owners or company applicants.
FinCEN Identifiers for Individuals
Individuals may electronically apply for FinCEN identifiers. In the application, an individual must provide their name, date of birth, address, unique identifying number and issuing jurisdiction from an acceptable identification document, and an image of the identification document – the same four pieces of personal information and image reporting companies submit about beneficial owners and company applicants in BOI reports (section 4.1). After an individual submits an application, the individual will immediately receive a FinCEN identifier unique to that individual.
Once a beneficial owner or company applicant has obtained a FinCEN identifier, reporting companies may report it in place of the otherwise required four pieces of personal information about the individual in BOI reports.
FinCEN Identifiers for Reporting Companies
Your company may request a FinCEN identifier when it submits a BOI report by checking a box on the reporting form.
Updates or Corrections
When the information an individual or reporting company reported to FinCEN to obtain a FinCEN identifier changes, or when the individual or reporting company discovers that reported information is inaccurate, the individual or reporting company must update or correct the reported information, as applicable. See Chapter 6 for more information on the update and correction requirements, including timelines.
