Beneficial Ownership Reports

A reporting company must disclose the following information about each of its beneficial owners:

1. Full legal name,

2. Date of birth,

3. Current street address,

4. A unique identifying number from an acceptable identity document (such as an unexpired drivers license or passport), and

5. An image file of the document that provides the unique identifying number.

The current street address for a beneficial owner must be the beneficial owner's residential street address.

In the case of a company applicant who forms or registers a reporting company in the course of the company applicant's business, the company applicant's reported address should be the street address of the company applicant's business.

Special Rule for Company Applicants

Reporting companies that are formed or registered after January 1, 2024, must also provide information about their "company applicants."

The Final Rule defined "company applicant" as (1) the individual who files the reporting company's constituent documents (in the case of a domestic reporting company) and (2) the individual who files the document that first registers the reporting company to do business in the U.S. (in the case of a foreign reporting company).

In any case where there is more than one individual involved in filing the document, the "company applicant" should be "the individual who is primarily responsible for directing or controlling such filing" according to the Final Rule.