It depends. There are a number of potential exemptions from these beneficial ownership information reporting requirements. For example, pooled investment vehicles that are operated or advised by (1) a registered investment adviser or (2) a venture capital fund adviser are likely exempt from the reporting requirements. You will need to ensure your entity meets all the requisite criteria. FinCEN’s Small Entity Compliance Guide includes several checklists to help determine if your entity meets the exemption requirements.
The best way to determine your specific obligations is to speak with qualified legal counsel on the topic.
For more information on the new filing, we encourage you to visit FinCEN’s website. Detailed guidance, direct access to the new filing system, and additional FAQs can be accessed here: https://www.fincen.gov/boi.