Question for solo practitioners who are forming LLC's this year. Given the reporting requirements for Company Applicants under the Corporate Transparency Act, what are your thoughts on providing your residential address (assuming you dont have a business address)? Moreover, do any of you anticipate changing the way you provide formation services due to CTA reporting requirements?

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I don’t understand the question. You have to upload your drivers license or passport. There’s no way around providing your residential address if you use a drivers license.

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A FINCEN ID can be used for the beneficial owner as well. I just did it with the LLC I have for my side hustle…. But as others have said Treasury already has your residential address from your tax return

I already got a FINCEN ID- I will use that . I used residential when I applied for FINCEN ID

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Sure

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I got a FinCen ID too just to save on some time if I’m filing a lot of these

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Not a solo practitioner, but our small firm is not doing any formations under the current CTA construct. It's more than just a residential address. You're signing up for a lifetime update obligation, and you have no control over who might ultimately own the entity years down the line. Not to mention the possibility that you get a FinCEN ID number that is compromised, and now you're attached to entities that you never even formed and you'll never know until/unless Treasury comes knocking because there's no way to monitor the database for a certain ID on this end of things.

What a disaster of a law.

If any person in our office gets a FinCEN ID, it will come with a lifetime update obligation for that individual. Otherwise, attorneys pushing out formations will have to add their driver's license or passport number to each formation they do. And recent guidance indicates that the preparing attorney is a company applicant even if they outsource the actual filing to a servicer like CSC. We'll still draft formation documents, but we'll be delivering them to the client with instructions on how to file through a service company.

As far as the "current construct" piece, I suspect that the law will be amended before too long to allow company applicants to obtain an entity-level FinCEN ID that is tied to the firm rather than any individual lawyer or staff member. If that change is implemented, we'll resume formation filings.

Guys the government already has your residential address lol. Get a fincen ID so you don’t have to supply your personal info to your clients. Fincen is the department of treasury- they know everything about you.

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