4.2 What do I report if a special reporting rule applies to my company?

The Reporting Rule includes four special reporting rules that may affect your company's reporting obligations.

  1. Owned by exempt entity: You do not need to report information about any beneficial owner whose ownership interests in a reporting company are held through one or more entities, all of which are themselves exempt from the reporting company definition. Refer to Chapter 1.2 for the types of entities that are exempt from the reporting company definition.

    > If this special rule applies, then you may report the names of all of the exempt entities instead of information about the individual who is a beneficial owner of your company through ownership interests in those exempt entities.

    Example: A large operating company owns 50% of the ownership interests in your company. Large operating companies are exempt from the reporting company definition (see Exemption #21). Individual A owns 50% of the large operating company, and therefore owns 25% of the ownership interests in your company (50% × 50% = 25%). You may report the name of the large operating company instead of Individual A's personal information.

  2. 2. Minor child: You do not need to report information about a beneficial owner of the reporting company who is a minor child, provided you have reported the required information about the minor child's parent or legal guardian.

    > If this special rule applies, you may report the required information about the child's parent or legal guardian instead of the child.

    Note: If you report a parent or legal guardian's information instead of a minor child's information, then you must indicate in your BOI report that the information relates to a parent or legal guardian of the minor child.

  3. 3. Foreign pooled investment vehicle: You do not need to report information about each beneficial owner and company applicant if your company was formed under the laws of a foreign country and would be a reporting company if not for the pooled investment vehicle exemption (Exemption #18).

    > If this special rule applies, you must report one individual who exercises substantial control over the company. You do not need to report any company applicants. If more than one individual exercise substantial control over the company, you must report information about the individual who has the greatest authority over the strategic management of the company.

  4. 4. Company applicant reporting for existing companies: If the reporting company was created or registered before January 1, 2024, you do not need to report any company applicant information for the reporting company.

    > If this special rule applies, do not report company applicants. Specify on the BOI report that the company was created or registered before January 1, 2024.