Beneficial ownership
Beneficial ownership refers to anyone who enjoys the benefits of owning a security or property without being on the record as an owner.
When you open a business account, update a current one, or apply for a loan, federal law requires us (and you) to identify and provide information about your beneficial owners — each individual who owns 25% or more of the legal entity and a single control person who has managerial responsibility for it.
It’s quick, painless, and helps safeguard against terrorism funding and money laundering schemes.
Information you need to provide
- Name
- Address
- Date of birth
- Social security number
Acceptable forms of identification
- Driver’s license
- State identification card
- Passport
- Resident alien card
Reporting Requirement for Beneficial Ownership Information
Beginning on January 1, 2024 many companies in the United States will have to report information about their beneficial owners, i.e., the individuals who ultimately own or control the company. They will have to
report the information to the Financial Crimes Enforcement Network (FinCEN). FinCEN is a bureau of the U.S. Department of the Treasury.
The Corporate Transaction Transparency Act was passed by Congress in 2021, creating a beneficial ownership information reporting requirement as part of the U.S. Government’s efforts to make it harder for bad actors to hide or benefit from their ill-gotten gains through shell companies or other opaque ownership structures.
The Reporting Rule, issued on September 30, 2022, requires certain entities to file beneficial ownership reports to FinCEN. The reports contain information about the entity itself and the beneficial owners and company applicants.
FinCEN began accepting beneficial ownership information on January 1,2024.
New Reporting Companies
- created or registered to do business in the United States on or after January 1, 2024
- Reports due within 90 calendar days of receiving actual or public notice that the creation or registration of the reporting company is effective
Existing Reporting Companies
- created or registered to do business in the United States before January 1, 2024
- Reports due by January 1, 2025
While certain types of entities are exempt, if you are a small corporation or LLC, you will most likely be required to report your beneficial ownership information to FinCEN. For more information, go to fincen.gov/boi
Go to fincen.gov/boi to file.
Important definitions
Each individual with 25% or more equity interest in the legal entity, whether directly or indirectly
Single individual with significant responsibility to control, manage, or direct a legal entity customer (e.g., executive officer or senior manager)
An individual authorized to open accounts or provide information on behalf of the legal entity
- Corporation
- Limited liability company
- Partnership
- Other entity created by filing a public document with a secretary of state or similar office
- General partnership
- Any similar entity formed under the laws of a foreign jurisdiction that opens an account
Note: A legal entity does not include sole proprietorships or unincorporated associations.
Have questions?
Our business banking team can provide more detail about beneficial ownership disclosure and help you with all your banking needs.