FAQs

Question: Should I get a FinCEN Identifier?

Answer:  It depends.  If you do not own 25% or more of a reporting company and do not control a reporting company you do not need a FinCEN identifier.  However, if you own 25% or more of more than one reporting company or have substantial control of more than one reporting company I recommend that you get a FinCEN identifier because it will make it very simple for you to give your personal information to reporting companies.

Instead of giving a reporting company your legal name, birth date, business or residence address and number from your driver’s license, state id card or passport you merely give the reporting company your FinCEN identifier.

Hire Us to Get You a FinCEN Identifier

Go to our FinCEN identifier page to hire us to get your FinCEN identifier.

Question:  What is a FinCEN identifier?

Answer: A FinCEN identifier is a code issued by FinCEN to a person or an entity that can be used to identify the person or entity in a FinCEN report.  When a FinCEN identifier is used in a FinCEN report that required information about the beneficial owner or applicant does not have to be included in the report.

Question:  If a Trust owns 25% or more of a reporting company is the trustee a beneficial owner of the reporting company?

Answer:  Yes.  A beneficial owner of a reporting company is any individual who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise exercises substantial control over the entity or owns or controls not less than 25 percent of the ownership interests of the reporting company.

The trustee of a trust is the legal owner of the trust’s assets.  Normally the trustee’s ownership of a reporting company will satisfy the criteria set forth above, which makes the trustee a beneficial owner of the reporting company and the trustee’s information must be disclosed on the reporting company’s FinCEN report.

All trustees of a trust that satisfies the criteria set forth above are beneficial owners of the reporting company.  If Homer and Marge Simpson are trustees of their family estate planning trust that owns 25% or more of a reporting company then both of them must disclose their information on the reporting company’s FinCEN report.