Business Ownership Documents
To onboard a business at Fin.com, we need to verify who owns and controls the company. This guide explains which documents we accept based on your business type.Key Points
- 25% Rule: We are required to identify every individual who ultimately owns or controls 25% or more of the business.
- Verification: You must either have a “Control Person” attest to the ownership structure or provide official documentation to prove it.
Definitions
- Ultimate Beneficial Owners (UBO): Any person who has final ownership or control over the business entity.
- Control Person: Someone with significant responsibility to manage the business, such as a CEO, CFO, COO, President, or Director.
Ownership Structure Attestation
If the person completing the onboarding is a Control Person, they can simply attest that the information provided covers all UBOs with 25% or more ownership.Ownership Document Requirements
If a Control Person doesn’t provide an attestation, we’ll need an official document that confirms the ownership structure.- Signatures: Any self-generated lists of shareholders must be signed and dated by a verified Control Person, a lawyer, or a third-party CPA.
- Equity Platforms: Reports from well-known platforms like Carta, AngelList, or Securitize are accepted without extra signatures.
- Total Coverage: The document must clearly account for 100% of the company’s ownership.
- Parent Companies: If your business is owned by another company, we will need documents for that parent company as well until we reach the individual owners.
- Control Focus: If your entity doesn’t have individual owners (like a nonprofit), we will verify the directors and officers instead.
Acceptable Ownership Documents By Entity Type
Sole Proprietorships
Sole Proprietorships
- Business License–listing the sole proprietor as the owner
- Trade Name Registration (DBA)—indicating the owner if the business operates under a different name
- **Tax Filings: **Individual tax returns (Schedule C) showing business income and expenses reported by the sole proprietor
Partnerships
Partnerships
- General Partnerships (GP)
- Partnership Agreement–listing the partners and their respective ownership interests
- Certificate of Partnership–if the partnership is registered, listing the partners
- Trade Name Registration (DBA)—including information on the multiple partners
- Limited Partnerships (LP)
- Certificate of Limited Partnership–filed with secretary of state or similar government body, naming the general and limited partners
- Limited Partnership Agreement–detailing the ownership structure, roles, and contributions of each partner
- Schedule of Partners–listing all partners and their ownership percentages
- K-1 Forms–issued to partners for tax purposes, showing their share of profits or loss
- Limited Liability Partnership (LLP)
- Registration of Limited Liability Partnership–filed with secretary of state or similar government body, listing the partners
- LLP Agreement–listing the partners and their ownership interests
- K-1 Forms–for tax filings, indicating the limited partner’s’ share of profits or losses
Corporations
Corporations
- Articles of Incorporation–listing the shareholders
- Note: control persons (directors/officers) listed without shareholders are not sufficient. Please ensure that this document confirms the entity’s shareholders, which are not necessarily one in the same as the entity’s directors, officers, or incorporators
- Stock Certificates–issues to shareholders, representing ownership in the corporation
- Shareholder Ledger or Cap Table– listing all shareholders and their ownership percentages
- Shareholders’ Agreement–listing shareholders and their ownership percentages
- Board Meeting Minutes–listing shareholders and their ownership percentages
- SEC Filings (for public companies)—including information on significant shareholders and controlling parties
- K-1 Forms–provided to shareholders, showing their share of the corporation’s profit or loss
Limited Liability Company (LLC)
Limited Liability Company (LLC)
- Articles of Organization–filed with the secretary of state or similar government body, sometimes listing the members (owners)
- Operating Agreement–detailing the ownership structure, members’ contributions, and percentages of ownership interest
- Membership Certificates–issued to members to represent their ownership interest in the LLC
- Membership Ledger–internal document tracking all members and their ownership interests
- K-1 Forms–provided to members, showing their share of the LLC’s profit or loss
- IRS 147(c) EIN Letters–for sole-member LLCs
Nonprofit Organizations
Nonprofit Organizations
Nonprofit Organizations usually do not have individual beneficial shareholders. We are required to confirm control person(s) instead.
- Articles of Incorporation–filed with the secretary of state or similar government body, listing directors or founders
- Bylaws–defining the governance structure, listing directors and officers
- Board Meeting Minutes–documenting decisions and changes in the controlling parties, board members, directors, and officers
- IRS Determination Letter–confirming the nonprofit’s tax-exempt status including details on controlling parties
- Annual Reports–filed with the secretary of state or similar government body, listing current directors and officers
Foundations
Foundations
Foundations usually do not have individual beneficial shareholders. We are required to confirm control person(s) instead.
- Articles of Incorporation–filed with the secretary of state or similar government body, listing initial directors or founders
- Trust Documents–establishing the foundation, listing trustees or board members
- Bylaws–defining the governance and control structure
- Board Meeting Minutes–detailing the actions and changes in the foundation’s controlling parties
- IRS Determination Letter–confirming the nonprofit’s tax-exempt status including details on controlling parties
- Annual Reports–filed with the secretary of state or similar government body, listing current directors and officers
Decentralized Autonomous Organizations (DAOs)
Decentralized Autonomous Organizations (DAOs)
- Membership Agreements–outlining the ownership percentages of members or token holders
- Voting Records–documenting decisions and controlling parties based on token voting or other consensus mechanisms
- Other Documents:
- White Paper
- Membership or Token Agreement
- Governance Framework
Trusts
Trusts
- Trust Deed–establishing the trust and outlining the roles of the trustors, trustees, beneficiaries, and terms of the trust
- Certificate of Trust–proving the existence of the trust and the trustee’s authority
- Notarized Trustee’s Affidavit–confirming the identity and authority of the trust parties
Cooperatives
Cooperatives
- Articles of Incorporation–filed with the state, establishing the cooperative listing its members
- Membership Agreement–outlining the terms of membership, rights, and responsibilities of cooperative members
- Membership Ledger–listing all members and their ownership stakes or voting rights
- Members’ Meeting Minutes–documenting decisions made by the members and any changes in membership or control
- Share Certificates (if applicable)—representing ownership stakes or member contributions in the cooperative
Other Ways to Confirm Ownership
If the documents above aren’t available, you can use:- Ownership Org Charts: A visual map showing how different units and individuals own the company.
- Signed Attestation Letter: A letter confirmed by a lawyer or CPA listing all UBOs and their percentages.
- Certified Cap Table: A list of shareholders signed by a third-party CPA or lawyer.