What if Beneficial Owner or Applicant Does Not have a Permanent Residential Address?

Question: What residential address should be reported if a reporting company is required to report an individual’s residential address, but that individual does not have a permanent residential residence?

Answer: The residential address that is current at the time of filing should be reported to FinCEN. An updated report should be submitted within 30 calendar days if the address, or any other information previously reported, changes.

Can a Picture be Omitted on an ID Image for Religious Reasons?

Question: If a beneficial owner or company applicant’s acceptable identification document does not include a photograph for religious reasons, will FinCEN accept the identification document without the photograph?

Answer: Yes. If a beneficial owner or company applicant’s identification document does not include a photograph for religious reasons, the reporting company may nonetheless submit an image of that identification document when submitting its report, as long as the identification document is one of the types of identification accepted by FinCEN, such as a non-expired State-issued identification document.

What are Acceptable Forms of Identification?

Question: What are some acceptable forms of identification that will meet the reporting requirement?

Answer: The only acceptable forms of identification are:

  1. A non-expired U.S. driver’s license (including any driver’s license issued by a commonwealth, territory, or possession of the United States);
  2. A non-expired identification document issued by a U.S. state or local government, or Indian Tribe;
  3. A non-expired passport issued by the U.S. government; or
  4. A non-expired passport issued by a foreign government (only when an individual [. . .]

What Applicant Info is Disclosed in a FinCEN BOI Report?

Question: What information will a reporting company have to report about its company applicants?

Answer: For each individual who is a company applicant, a reporting company will have to provide:

  1. The individual’s name;
  2. Date of birth;
  3. Address; and
  4. An identifying number from an acceptable identification document such as a passport or U.S. driver’s license, and the name of the issuing state or jurisdiction of the identification document.

The reporting company will also have to report an image of the identification document used to [. . .]

What Causes an Individual to Become a Company Applicant?

Question: The company applicants of a reporting company include the individual “primarily responsible for directing the filing of the creation or registration document.” What makes an individual “primarily responsible” for directing the filing?

Answer:  At most, two individuals need to be reported as company applicants:

  1. the person who directly files the document with a secretary of state or similar office, and
  2. if more than one person is involved in the filing of the document, the person who is primarily responsible for directing or controlling [. . .]
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