FINCEN IDENTIFIER NUMBERS

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WHAT IS A FINCEN IDENTIFIER NUMBER?

A FinCEN Identifier is a unique number that FinCEN will issue upon request after receiving required information.

Although there is no requirement to obtain a FinCEN Identifier, doing so can simplify the reporting process and allows entities or individuals to quickly reference identifying information previously provided to FinCEN.

We are recommending that you should get a FinCEN identifier if you are connected with multiple Reporting Companies.

Why Are We Recommending You Get A FinCEN Identifier?

1) If you are involved with multiple reporting companies, you only need to submit your personal information into the system once. After that, you just use your FinCEN Identifier Number and you don't have to resubmit your personal information over and over and over ...

2) If anything changes with your personal info (such as a change of your address), you only need to file one updated FinCEN Identifier number report and your updated information will automatically be carrier over to all the other entities you're involved in. Again, you only have to file the update once ...

3) It's a more secure way for you to keep your information private. When a reporting company asks you for your personal info (such as home address, date of birth and copy of driver's license or passport), all you need to do is give them your FinCEN Identifier number and you're done.

If you want to get a personal FinCEN Identifier number, we can help you with that process if you need help.

How Do You Obtain a FinCEN Identifier?

REPORTING COMPANIES may request a FinCEN Identifier by checking a box on the beneficial ownership information report when they submit the report. After the reporting company submits the report, the reporting company will immediately receive a FinCEN identifier unique to that company.

INDIVIDUALS may obtain a FinCEN Identifier by filing an application electronically with FinCEN that contains certain information about themselves. FinCEN will store such information in its BOI database for access by authorized users. As with other BOI data submitted to FinCEN, filers must update information submitted to apply for a FinCEN Identifier, such as changes to addresses or document ID numbers within 30 days of that change.

If you want to get a personal FinCEN Identifier number, we can help you with that process if you need help.

Who can request a FinCEN identifier on behalf of an individual?

Anyone authorized to act on behalf of an individual may request a FinCEN identifier on the individual’s behalf.

FinCEN identifiers for individuals are provided upon request after the requesting party has submitted the necessary information. Obtaining a FinCEN identifier for an individual requires the requesting party to create a Login.gov account, which is tied to the individual receiving the FinCEN identifier. Individuals who receive a FinCEN identifier should ensure their login credentials, including email address and related multi-factor information associated with their Login.gov account, are saved for future reference.

Are FinCEN identifiers required?

No. An individual or reporting company is not required to obtain a FinCEN identifier.

Do you need to update or correct the information I submitted to obtain a FinCEN identifier?

Yes. Individuals must update or correct information through the FinCEN identifier application that is also used to request a FinCEN identifier.

Individuals must report any change to the information they submitted to obtain a FinCEN identifier no later than 30 days after the date on which the change occurred.

If there is any inaccuracy in this information, an individual must correct the information no later than 30 days after the date the individual became aware of the inaccuracy or had reason to know of it.

Reporting companies with a FinCEN identifier must update or correct the company’s information by filing an updated or corrected beneficial ownership information report, as appropriate.

Is there any way to deactivate an individual’s FinCEN identifier that is no longer in use so that the individual no longer has to update the information associated with it?

FinCEN is actively assessing options to allow individuals to deactivate a FinCEN identifier so that they do not need to update the underlying personal information on an ongoing basis. FinCEN will provide additional guidance on this functionality upon completion of that process.

DISCLAIMER

Stanley Bronstein is a lawyer and a CPA, but he is not your lawyer or CPA unless and until he is hired by you as your lawyer and/or CPA. The information and opinions contained herein are just that, information and opinions intended to help you learn about and understand your filing requirements under the new Corporate Transparency Act. The information contained herein should not be considered to be the giving of legal advice or accounting advice, unless and until you hire Stanley Bronstein as your lawyer and/or CPA.