The Corporate Transparency Act (CTA) requires certain companies (called “reporting companies”) to file a report with the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) containing the company’s beneficial owners and company applicants’ personal identifying information.
Beneficial owners and company applicants may report the required information directly to their company (or companies), which will then either compile and file it with FinCEN themselves or use a third-party filing partner to do it for them. Most companies will likely use an outside solution to file their beneficial ownership and company applicant information for the same reasons they file their tax documents through an accountant—it’s easier and it transfers liability to another source.
However, some parties may choose to apply for a FinCEN identifier (also called a reporting number) instead.
A FinCEN identifier is a unique number FinCEN issues to either individuals or reporting companies. An individual can apply for a FinCEN reporting number by supplying the requisite information directly to FinCEN instead of to their reporting company. This information includes:
- Full name
- Date of birth
- Current street address
- A unique identifying number from an acceptable identification document
- A scanned image of that document
Applicants must also submit updates of their identifying information as needed.
When these individuals receive their FinCEN identifier, they can provide it to the reporting company instead of the information otherwise required. FinCEN will then be able to look up this number in its database to retrieve the information.
Additionally, a reporting company can apply for a FinCEN identifier containing all the information that would be required on its initial report. The company can apply for this number at the same time or after it submits its initial report and can then use the FinCEN identifier rather than supplying all of its information every time it files an update.
Possible Benefits of Using a FinCEN Identifier (Reporting Number)
FinCEN suggests that the primary incentives for individuals to apply for an identifier are:
- Data Security – Some people may not want to send personal information to a reporting company but would rather file their data with FinCEN directly. Additionally, company applicants that are responsible for registering with several reporting companies may choose to request a reporting number to limit the number of companies that have access to their personal information.
- Administrative efficiency – As mentioned in the previous point, some people may be beneficial owners in more than one reporting company, in which case it would be easier to submit one number than it would be to submit all their information multiple times.
- Anonymity – If an individual doesn’t directly own a reporting company but rather indirectly owns it through another entity, that person may wish to remain anonymous. Individuals who have direct ownership in reporting companies may be less inclined to apply for a FinCEN identifier because their reporting company already knows their identity.
Estimated Number of Applicants
Because the motives listed above don’t apply to the majority of beneficial owners and company applicants, FinCEN estimates the number of people who will apply for a FinCEN identifier may be relatively low. In fact, they currently estimate that number to be approximately one percent of total filers. Most people simply won’t need it.