As the new year has begun, so have the reporting requirements of the Corporate Transparency Act. As a follow up to our September 14, 2022 article “An Introduction to the Corporate Transparency Act,” and our December 23, 2023 article “Basic Overview of the Corporate Transparency Act (CTA),” this article outlines the process of applying and obtaining a FinCEN Identifier (ID) to use in connection with CTA reporting requirements. Please refer to our other articles for more information about the CTA and reporting requirements under the federal law.

FinCEN ID

A “FinCEN identifier” or “FinCEN ID” is a unique identifying number issued to an individual or an entity by the Financial Crimes Enforcement Network (FinCEN). Although not required, individuals may apply for and obtain a FinCEN ID to disclose as part of a Beneficial Ownership Information Report (BOIR). Reporting companies may report the FinCEN ID of an individual on a BOIR rather than such individual’s required personal information. A FinCEN ID is intended to speed up and facilitate the process of completing BOIRs.

Applying for a FinCEN ID

Individuals must apply for a FinCEN ID through FinCEN’s FinCEN ID Application portal located at https://fincenid.fincen.gov. Once on the official page, sign in or create an account with FinCEN and login. If you have not already done so, you will need to create an account with Login.gov first. Once you reach the FinCEN ID Application, complete the following steps:

1. Enter your information in the First Name, Middle Name (if applicable) Last Name, Suffix (if applicable) and Date of Birth
2. Select Address Type and enter applicable address: Residential Address or Business Address.

• • For company applicants, report the street address of such business.
  • Multiple addresses can be added or removed, if necessary.

1. Select an identifying document type and provide applicable information: State-issued driver’s license, State/local/Tribe issued ID, U.S. passport, or foreign passport.
   • A foreign passport is only acceptable if an individual does not have one of the other identifying documents.
2. Upload a copy of the required identifying document.
   • Supported formats are JPG/JPEG, PNG, and PDF.
   • Maximum file size is 4MB.
3. Review and confirm required certification.
4. Click the Submit

Once submitted, you should receive a submission receipt and your unique FinCEN ID. Be sure to download a copy of the PDF submission receipt for your records. For further assistance with the FinCEN ID Application and to review a screenshot of the application, please refer to FinCEN’s Quick Reference Guide located at https://fincenid.fincen.gov/assets/helpContent/FinCEN-ID-Quick-Reference-Guide-20240110.pdf and the FinCEN Identifier Application: Filing Instructions located at https://fincenid.fincen.gov/assets/helpContent/FinCEN-ID-Instructions-20240101.pdf.

Correcting or Updating a FinCEN ID

To correct or update information associated with a FinCEN ID, login to the FinCEN ID Application portal again. Once online, select the correct or update prior report button and enter the corrected or updated information, as applicable. Leave all correct or unchanged information as is. Submit the changes with the revised FinCEN ID application. A new download receipt should become available reflecting the corrected or updated information, but the FinCEN ID will not change.