New Registry Requirements for Reporting Companies: What You Need to Know
As of January 1, 2025, reporting companies created before January 1, 2024, are required to file an initial report with the Financial Crimes Enforcement Network (FinCEN) regarding their beneficial owners and company applicants. This article provides a comprehensive overview of the requirements for reporting companies and beneficial owners.
Initial Report Requirements
Reporting companies must provide information about themselves, including:
- Full legal name
- Trade or “doing business as” names
- Complete current address
- State, tribal, or foreign jurisdiction of formation
- IRS Taxpayer Identification Number (TIN) or equivalent foreign tax identification number
For beneficial owners, reporting companies must provide the following information:
- Full legal name
- Date of birth
- Complete current address
- Unique identifying number and issuing jurisdiction from a valid government-issued ID document
- Image of the ID document
Reporting Company Information
Companies created before January 1, 2024, are only required to report information about themselves and their beneficial owners. They do not need to provide company applicant information.
Updated Reports
Reporting companies must file updated reports within 30 calendar days after any changes occur regarding:
- Beneficial ownership
- Information reported for a particular beneficial owner
However, reporting companies are not required to update previously reported information about company applicants. They will only be required to correct inaccurate information previously reported.
Corrected Reports
If a report contains inaccurate information and remains inaccurate, the reporting company must file a corrected report within 30 calendar days after becoming aware of the inaccuracy.
Changes in Status
Reporting companies that no longer meet exemption criteria or become exempt subsequent to filing an initial report must file an updated report within 30 calendar days.
FinCEN Identifier
A FinCEN identifier is a unique number issued by FinCEN to individuals and reporting companies. Individuals can obtain a FinCEN identifier by submitting an application, which can be used in lieu of the information required for the initial report. Reporting companies can also obtain a FinCEN identifier and use it in place of the information required for beneficial owners.
Updates and Corrections
Individuals who have obtained a FinCEN identifier must file updated or corrected applications within 30 calendar days after any changes occur. Reporting companies that have obtained a FinCEN identifier are required to file updated or corrected reports reflecting changes in their own information.
In summary, reporting companies created before January 1, 2024, must file an initial report with FinCEN by January 1, 2025, providing information about themselves and their beneficial owners. Reporting companies must also update or correct reports if any changes occur regarding beneficial ownership or company information.