What is a FinCEN Identifier (FinCEN ID)?

The implementation of the Corporate Transparency Act (CTA) has left clients with some important questions when reporting the Beneficial Owners within the BOI Report submitted to the Financial Crimes Enforcement Network (FinCEN), a division of the US Treasury Department.  While determining whether your company must or is exempt from filing this report with FinCEN is determined internally and sometimes with the help of an attorney, clients sometimes wonder what specific information needs to be provided.

While the information that you need to provide may vary, and the reporting requirements generally weed out any bad apples, when completing the process of submitting the BOI Report with FinCEN as a company applicant, in lieu of providing specific personal information when submitting the report, individuals can also provide a FinCEN Identification Number (FinCEN ID). The FinCEN ID is another avenue for you to identify yourself without having to provide further personal information.  It’s more convenient to use a FinCEN ID and it’s also more secure, as it will reduce the amount of personal information that would otherwise be circulated. It’s essentially one more number in the world that can be used to identify you or your business.

For Delaware formations, a company applicant is the person who directly files the formation documents with the Delaware Secretary of State for approval.  In addition to the person who files the documents with the state for approval, the individual that signs the Certificate filed with the state could be also be considered a company applicant as well.

For instance, many accountants, paralegals, attorneys, and business formation specialists, such as those at Harvard Business Services, Inc. (HBS), obtain FinCEN ID numbers.  When HBS assists clients with forming Delaware companies, the individuals at HBS submitting the formations to the Delaware Secretary of State for approval will have a FinCEN ID Number and provide it to our clients after the formation process with the approved formation packet.  Every member of our Filings Team that submits a filing to create an entity will have their own unique FinCEN ID that we provide to clients with each formation.  For clients that form companies routinely, the FinCEN ID could be different depending on the individual that files the document with the state.  Individuals that are a part of several entities at once may also apply for a FinCEN ID to streamline the BOI Report submission and editing processes.

Sometimes, clients with a high volume of companies do not want to provide in-depth personal information multiple times.  Using the FinCEN ID number allows them to be identified so that they won’t have to provide an ID to anyone and everyone.  It’s convenient and secure to provide a FinCEN ID so that personal information is not provided numerous times.

It’s important to note that these new reporting requirements are for any entities formed in 2024. The reports currently must be provided within 90 days of the company’s formation. Companies established before January 1st, 2024, have until the end of 2024 to complete the initial filing with FinCEN.

At this time, HBS does not have a service to help complete the FinCEN filings.  However, HBS has partnered with FinCEN Report Company. They provide a platform for companies to file beneficial ownership information (BOI) in accordance with the Corporate Transparency Act.   You can also complete the filing directly with FinCEN by using this link.

If you have any questions about forming a new company, feel free to contact us at 1-302-645-7400 or 1-800-345-2677 ext. 6900 or via email at info@delawareinc.com. We can also be reached via skype at delawareinc.