The requirement to report company applicants applies solely to reporting companies established or registered after January 1, 2024. Companies formed before 2024 are not obligated to disclose their company applicant(s) information.
A reporting company obligated to report its company applicant(s) can identify up to two individuals who:
- Directly submits the document, establishing or registering the reporting company
- Are primarily responsible for directing or controlling the filing process (in some cases, this may involve multiple individuals)
For example, an attorney at a law firm providing business formation services may oversee the preparation and filing of a reporting company’s incorporation documents. If a paralegal directly files the documents at the attorney’s direction, both the attorney and the paralegal are considered company applicants for the reporting company.
A maximum of two individuals may be submitted as company applicants (not a company).