Submitted by UCS on November 8, 2023

What is a FinCEN Identifier?

Of the changes coming with the new legislation regarding the Corporate Transparency Act (“CTA”), a new government identifier will be obtainable to streamline the process of submitting Beneficial Owner Information (BOI) reports and fill out company applicant information. This new identifier is called the FinCEN Identifier and is sometimes referred to as a “FinCEN number” or a “FinCEN ID” in various reports on the CTA.

FinCEN Identifier defined

Here is FinCEN’s definition: “A ‘FinCEN identifier’ is a unique identifying number that FinCEN will issue to an individual or reporting company upon request after the individual or reporting company provides certain information to FinCEN. An individual or reporting company may only receive one FinCEN identifier.”

The following is valuable information regarding this ID taken from FinCEN’s Small Business Compliance Guide:

• An individual or reporting company is not required to obtain a FinCEN identifier.
• An individual or reporting company may only receive one.
• Your company may include FinCEN identifiers in its BOI report instead of certain required information about beneficial owners or company applicants.

What information do you need to provide to FinCEN?

FinCEN explains that obtaining and using a FinCEN ID is a way to protect personal information. Since the process of receiving a FinCEN ID requires providing an individual’s “full legal name, date of birth, address, unique identifying number and issuing jurisdiction from an acceptable identification document, and an image of the identification document,” this information is not additionally needed on a BOI report. So, Beneficial Owners or Company Applicants who obtain a FinCEN ID will be able to use this ID instead of putting the above personal information on a BOI report which may be seen by paralegals, service company employees, attorneys, and, naturally, beneficial owners as well as the public at large.

In their small business compliance guide, FinCEN states that applications for FinCEN Identifiers will be immediately processed upon inputting the required information on their portal. The portal will be on FinCEN’s website beginning January 1, 2024. Additionally, a reporting company may opt in when submitting their BOI report to receive their FinCEN ID, and this will likewise be immediate along with the BOI report submission.

Conclusion

One last thing to note is regarding the upkeep of a FinCEN ID. Any change of personal information included in the application of your FinCEN identifier must be reported on FinCEN’s website within 30 days of the change. FinCEN has not stated whether these FinCEN identifiers will be able to be deactivated—FinCEN is “assessing options to allow individuals to deactivate a FinCEN identifier so that they do not need to update the underlying personal information on an ongoing basis.”

For more details on the reporting requirements of the Corporate Transparency Act you may visit the FinCEN website or utilize the United Corporate Services, Inc. CTA Reference page on our website. 

About the authors

Ray Barr is an independent writer and video editor who is presently pursuing a Master of Fine Arts in Creative Writing at The New School. He completed his undergraduate studies in Classical Civilizations at The University of Richmond, where he also explored various disciplines such as History, Anthropology, Environmental Science, and Economics within the framework of a liberal arts education. Ray’s work has been featured in The Messenger literary magazine, and he was honored with The Margaret Owen Finck Award for Creative Writing for his outstanding piece titled “What’s Cooking”.

Keith Sheppard, a Business Development Manager at United Corporate Services, holds a Bachelor of Science degree in Paralegal Studies from St. John’s University. With an extensive career spanning over 27 years in the legal services industry, Keith has held various managerial roles, including Client Service Representative and Corporate Paralegal Manager. His wealth of experience enables him to offer valuable perspectives on effectively navigating the intricacies of corporate filing and uniform commercial code transactions.

Disclaimer: The content and materials which have been prepared by United Corporate Services, Inc. regarding the Corporate Transparency Act are for informational purposes only, and are not intended to provide, and should not be relied upon for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any future corporate formation transactions.  Content regarding the Corporate Transparency Act has been taken directly from FinCEN.  Additional information regarding the Corporate Transparency Act is available through the FinCEN website by clicking here or you can contact FinCEN directly with additional questions here.