New Federal Reporting Requirement for Beneficial Ownership Information (BOI)
In 2021, Congress enacted the Corporate Transparency Act. This law creates a beneficial ownership information reporting requirement as part of the U.S. government’s efforts to make it harder for bad actors to hide or benefit from their ill-gotten gains through shell companies or other opaque ownership structures.
Beginning on January 1, 2024, many companies in the United States will have to report information about their beneficial owners, i.e., the individuals who ultimately own or control the company. They will have to report the information to the Financial Crimes Enforcement Network (FinCEN). FinCEN is a bureau of the U.S. Department of the Treasury.
Be sure to review FinCEN’s Small Entity Compliance Guide, which provides information to help small businesses comply with this reporting requirement.
For more information please visit https://www.fincen.gov/boi
Beneficial Ownership Requirements
Effective May 11, 2018, new federal rules require us to identify and verify the beneficial owners of each account opened or modified for a covered legal entity.
Who is considered a Beneficial Owner?
Each individual who owns 25% or more of the business entity, and/or;
One individual who has significant responsibility to control, manage, or direct a business entity, such as a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, President, Vice President, Treasurer.
The rule applies to legal entity businesses such as a corporation, limited liability company, partnerships or another entity created by the filing of a public document with the Secretary of State or similar office, as well as a non-profit legal entity. However, a non-profit is only subject to identification and verification of the significant responsibility individual.
What will we ask you to provide?
When you open a new account or modify an existing account, we will ask you to identify the beneficial owners of your company, as defined above. We will need the following for each beneficial owner:
Date of Birth
Social Security Number
Current home address
Identifying information (driver's license, passport, etc.)
We will also ask you to provide the following business information and documents:
Federal Tax ID (IRS Form #147C)
State Filing Papers
Business formation documents such as: Operating Agreement, Articles of Incorporation, Organization By-Laws
If you have any questions or need additional information, please contact Customer Service at 610-767-3875.