How to gather information for FinCEN Beneficial Owner Filings?
We have added functionality into DecisionVault to help with taking in and handling the information related to FinCEN Beneficial Owner Report filings.
Learn more about our suggested approach in this blog post.
Suggested overall steps
Have the client fill in a DecisionVault (business) questionnaire. We have some components available that will help to gather information on reporting companies and (beneficial) owners - see below.
Counsel the client to help them identify who the beneficial owner(s) are for the entity/entities
Request for the client and the rest of the beneficial owners to register their individual FinCEN identifiers. You can send them an "external upload request" link to upload the registration confirmations for you to review - see below.
Use the online filing system of FinCEN to file the BOI Report, with the information on the reporting company and the FinCEN identifiers of the beneficial owners.
Components to help with FinCEN related information intake
Reporting Company Component
The "(FinCEN) Reporting Company" question can be added to the questionnaire and design sheets (you can add multiple to gather information on several companies in one go) - it will gather all the information on the reporting company that will also get asked on the BOI Report.
You can add "Group of People" custom questions below it to ask for people with ownership and/or substantial control:
External Upload Link
You can now add a document request - and create a temporary link that can be used by someone without a DecisionVault account to upload files to you (without seeing any of the existing information on the questionnaire/matter).
This starts with adding a document request from the matter screen, and then clicking 'Create link':
You can create a link for each of the people you are requesting information from - that way you'll see their name show up next to the date when a file was uploaded.
For more info on these external upload links - please see this support article: