Entity Compliance | Beneficial Ownership
Who owns and controls the entity, recorded and current.
Beneficial owners and control persons held against the entity, with the evidence behind each determination and a history of every change. Banks ask at account opening, lenders ask at facility renewal, counterparties ask during onboarding, and the reporting position has moved more than once. A maintained record answers all of them; a reconstructed one satisfies nobody.
What the system does
Capability, input, output.
| Capability | Input | Output |
|---|---|---|
| Ownership record | Owners and their percentages | Held per entity with the instrument or agreement supporting each |
| Control persons | Who exercises substantial control | Recorded with the basis, since control is not always ownership |
| Change history | A transfer, issuance or officer change | The position before and after, with the date it changed |
| Evidence | The document behind a determination | Attached to the record rather than filed separately |
| Look-through | Entities owned by other entities | The chain held, so the ultimate individual is derivable rather than assumed |
| Request response | A bank, lender or counterparty asking | Answered from the current record with its evidence, in one place |
-
Ownership record
- Input
- Owners and their percentages
- Output
- Held per entity with the instrument or agreement supporting each
-
Control persons
- Input
- Who exercises substantial control
- Output
- Recorded with the basis, since control is not always ownership
-
Change history
- Input
- A transfer, issuance or officer change
- Output
- The position before and after, with the date it changed
-
Evidence
- Input
- The document behind a determination
- Output
- Attached to the record rather than filed separately
-
Look-through
- Input
- Entities owned by other entities
- Output
- The chain held, so the ultimate individual is derivable rather than assumed
-
Request response
- Input
- A bank, lender or counterparty asking
- Output
- Answered from the current record with its evidence, in one place
Beneficial Ownership FAQ
What buyers ask.
Do we have to report this to anyone?
That depends on current rules and on your entity, and it is genuinely a question for your counsel or advisor right now rather than for a software page. The federal reporting position has changed more than once, and we would rather say so than print something that was true when it was written. What is not in doubt is that banks, lenders and counterparties ask, and that a current record is the only cheap way to answer.
Why keep this if reporting is uncertain?
Because the record is asked for by parties other than a regulator, and asked for at inconvenient moments: account opening, facility renewal, an acquisition, a counterparty onboarding you. Those requests do not wait while you work out who owns what.
What makes this hard?
Layered ownership and control that is not ownership. An individual with no equity can still exercise substantial control through a board seat or an agreement, and an entity owned through two holding companies needs the chain followed to reach a person. Both are judgements, so the basis is recorded rather than inferred.
How do we keep it current?
By treating a change in ownership or officers as an event that updates the record, rather than something reconciled annually. Where the stock ledger and the officer records live on the same entity, a transfer or appointment surfaces the ownership record that now needs review.
Who can see it?
Access is scoped tightly, and this is among the most sensitive records a company holds, since it is personal information about individuals. External access for a bank or counterparty is time-boxed and logged rather than granted as a folder.
More in Entity Compliance
Related features
Put your ownership record somewhere it stays current.
Connect your entities, free. Owners, control persons and the evidence behind each sit on the entity with their history.