Is my Management Company a reporting company?

It depends. There are a number of potential exemptions from these beneficial ownership information reporting requirements. For example, investment advisors that operate under the 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 a comprehensive checklist to help determine if you meet the exemption requirements.

The best way to determine your specific obligations is to speak with qualified legal counsel on the topic.

If you determine your Management Company has a filing obligation under the new rule, AngelList has tools to help. Through AngelList’s Stakeholder Portal, you can easily complete the initial FinCEN beneficial ownership information filing for free*.

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