Buy a FinCEN Beneficial Owner Information Report
Contents of FinCEN Reports Required by the Corporate Transparency Act (CTA)
The Corporate Transparency Act (CTA) provides that all “reporting companies” must file a report with the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury that discloses information or be subject to a $500/day fine. If your company is a reporting company then it must file a FinCEN report that contains the following information about each of its “beneficial owners” and the person called the “applicant.” See “Who Must File a FinCEN Report?“
A beneficial owner is an individual who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise (i) exercises substantial control over the entity, or (ii) owns or controls not less than 25 percent of the ownership interests of the entity. An applicant is the person who filed the reporting company’s formation document with the state agency of the state in which the entity was formed.
If you want to file a FinCEN Beneficial Owner Information report you cannot file it until you collect all of the reporting company, beneficial owner, and applicant information needed for the report. Here is a complete list of the information you need to file the report.
Reporting Company Information
A reporting company must provide the following information:
1. Legal name.
2. Any trade names, “doing business as” (d/b/a), or “trading as” (t/a) names.
3. The current street address of its principal place of business if that address is in the United States (for example, a U.S. reporting company’s headquarters), or, for reporting companies whose principal place of business is outside the United States, the current address from which the company conducts business in the United States (for example, a foreign reporting company’s U.S. headquarters) The address cannot be a P.O. box.
4. Its jurisdiction of formation or registration.
5. Its Taxpayer Identification Number (or, if a foreign reporting company has not been issued a TIN, a tax identification number issued by a foreign jurisdiction and the name of the jurisdiction).
Beneficial Owner Information
The reporting company must provide the following information about each of its beneficial owners:
1. Full legal name.
2. Date of birth.
3. Current, as of the date on which the FinCEN report is delivered, residential address.
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.
5. A scanned copy of the identification document from which the unique identifying number of the beneficial owner is obtained, in connection with reporting that unique number.
If you buy our FinCEN BOI report filing service the contact person will have two options for entering beneficial owner information:
1. The contact person enters the information, or
2. The contact person causes our online system to send an email to one or more beneficial owners asking them to enter their information into our online filing system.
When a company has multiple beneficial owners we recommend the contact person require unrelated people to enter their data into our system so the contact person has a defense to a FinCEN allegation that the contact person lied about the beneficial owner in the report. This feature is the main reason companies that have multiple unrelated beneficial owners should hire us to do their filings.
Applicant Information
Only companies formed after 2023 must disclose applicant information. To learn what an applicant is read our blog post called “What Causes an Individual to Become a Company Applicant?“
For each applicant, a reporting company must provide:
1. The individual’s name.
2. Date of birth.
3. Address. If the applicant works in entity formation—for example, as an attorney or corporate formation agent—then the reporting company must report the company applicant’s business address. Otherwise, the reporting company must report the applicant’s residential address.
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.
5. The reporting company will also have to report an image of the identification document used to obtain the identifying number in item 4.
FinCEN Identifier
In lieu of entering the above information in a FinCEN report the reporting company can report the FinCEN identifier FinCEN issued to the the person if that person submitted the above information to FinCEN and FinCEN issued the person a FinCEN identifier.
Go to https://fincenid.fincen.gov/landing to create a FinCEN Identifier.