Why You Need a FinCEN ID and When to Use It

Every individual who participates in a business or who is a member or manager of an LLC (or a General Partner in a Limited Partnership) should obtain an individual FinCEN ID. You can obtain one here

Your FinCen ID is unique to you as an individual. Think of it like a Social Security number that you only use for business. 

To get your FinCEN ID:

  1. You first have to create an account or login to an existing account at login.gov.  
  2. Then go to the FinCen ID site and complete the application. You will be asked to provide certain identifying information about yourself, such as your home address, date of birth, and driver’s license or passport number, so have it handy. 

You will use your FinCEN ID whenever anyone asks for required Beneficial Ownership Information (BOI) from you. For instance, you will use it when you file Beneficial Ownership Information Reports (BOIRs) at the FinCEN reporting site for any companies where you participate in control or own 25% or more of the company. Lenders may also request it. 

If you don’t get a FinCEN ID, you will need to provide your full name, home address, date of birth, and driver’s license or passport number every time you are asked for this information. You are then relying on the person to whom you provide it to safeguard it from identity theft. Just get the FinCEN ID and simplify your life. 

There are a number of exemptions for certain entities that don’t have to submit BOIRs, but none of them apply to Syndicators, Fund Managers, or real estate investors. 

You only have until December 31, 2024, to provide BOIRs for any company you own or control that was created before January 1, 2024.

For companies created after January 1, 2024, you only have 90 days from the date of formation to file your initial BOIRs. You must make amendments (by filing a new BOIR) within 30 days of any change in control, or admission of any member who acquires ownership of 25% of your company. 

You can file your BOIRs here.

You can obtain a FinCEN ID number for your entities as well as your individual FinCEN ID number, but the process for getting a company FinCEN ID is different.

You will request it when you are making your initial BOIR filing for your company.

Here’s how you can do this:

Go to FinCEN’s website BOIR filing page; click here.

You can choose to either prepare and file a PDF BOIR or do it online. If you are going to do it online you will need to have all the information they are going to request available at the time you do the filing. You may instead wish to download the PDF and complete it first and then do the online filing, or upload it later.

On the BOIR form, go to Part 1, Reporting Company Information, #3, and check the box to “Request to receive FinCEN Identifier (FinCEN ID).” FinCEN will then issue a FinCEN ID number for the company whose BOIR you are filing. From that point forward, whenever this company has to provide information as a Member of another entity, you will only need to provide the company’s FinCEN ID number.

You should encourage all of your investors to get their own FinCEN ID and report it to you at the time they subscribe to your company. If you need to include them in a BOIR for your companies, or to a Lender, you can use their FinCEN ID instead of having to securely house their sensitive identity information. Feel free to share this article with them, courtesy of SyndicationAttorneys.com

If you need help filing a BOIR or obtaining your FinCEN ID, you can visit FinCEN’s FAQ page or chat with them here. If you need help with forming an entity, syndicate, or fund, please schedule a call with Syndication Attorneys here.

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