FinCEN Seeks Comments on Proposed Collection for FinCEN Identifier

On January 17, 2023,  FinCEN issued a request for comments on the application that will be used to collect information from individuals who seek to obtain a FinCEN identifier, consistent with the Beneficial Ownership Information Reporting Requirements final rule that was published on September 30, 2022. Individuals who seek to obtain a FinCEN identifier must submit an application and update the information provided on the application as necessary. 

Highlights of the proposed information collection application include:

  • The final BOI reporting rule requires the collection of information from individuals in order to issue them a FinCEN identifier. This is a voluntary collection; however, in order to be issued a FinCEN identifier, the rule requires individuals to file applications electronically with FinCEN that contain certain information about themselves.FinCEN will store such information in its beneficial ownership information (BOI) database for access by authorized users.

  • Any individuals who meet the statutory criteria could apply for a FinCEN identifier under the rule. However, the primary reasons for individual beneficial owners to apply for a FinCEN identifier likely include data security and administrative efficiency. 

  • FinCEN estimates that the number of individuals who will apply for a FinCEN identifier will likely be relatively low, with an estimated total five-year average of 105,102 FinCEN identifier applications. The total five-year average of estimated FinCEN identifier updates is at 23,696. FinCEN also anticipates that initial FinCEN identifier applications would require approximately 20 minutes and updates would require 10 minutes.

Comments on the proposal will be accepted through March 20, 2023.

The full notice and request for comments can be found here.

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