When a beneficial owner or company applicant has obtained a FinCEN identifier, reporting companies may report the FinCEN identifier of that individual in the place of that individual’s otherwise required personal information on a beneficial ownership information report. An individual who is both a beneficial owner and a company applicant will receive only one FinCEN identifier.
A reporting company may report another entity’s FinCEN identifier and full legal name in place of information about its beneficial owners when three conditions are met:
(1) the other entity obtains a FinCEN identifier and provides it to the reporting
company;
(2) the beneficial owners hold interests in the reporting company
through ownership interests in the other entity; and
(3) the beneficial owners of the
reporting company and the other entity are the exact same individuals.
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