FinCEN BOI FAQ E.2
Which reporting companies are required to report company applicants?
Cite as FinCEN Beneficial Ownership Information FAQ E.2 (Company Applicant)
Not all reporting companies have to report their company applicants to FinCEN.
A reporting company
must report its company applicants
only if it is either a:
Domestic reporting company created in the United States
on or after January 1, 2024
; or
Foreign reporting company first registered to do business in the United States
on or after January 1, 2024
.
A reporting company
does not have to report its company applicants
if it is either a:
Domestic reporting company created in the United States
before
January 1, 2024; or
Foreign reporting company first registered to do business in the United States
before
January 1, 2024.
Below is summary of the company applicant reporting requirement. Chapter 3.1, “Is my company required to report its company applicants?” of FinCEN’s
Small Entity Compliance Guide
includes additional information.