Example 1: Mr. and Mrs. Smith each hold a 50% equity interest in Mom & Pop, LLC. Mrs. Smith is President and Mr. Smith is Vice President.
Mom & Pop, LLC would be required to identify at least two, but up to three individuals:
- Both Mr. and Mrs. Smith as beneficial owners
- Either Mr. or Mrs. Smith as a person with control, or a third person with significant responsibility
Example 2: Acme, Inc. is a closely-held private corporation. John Doe holds a 35% equity stake, and no other person holds a 25% or higher stake. Jane Jones is the President and Chief Executive Officer.
Acme, Inc. would be required to identify two individuals:
- John Doe as a beneficial owner
- Jane Jones (or another person with significant responsibility) as a person with control
Example 3: Quentin, Inc. is owned by the five Quentin siblings, each of whom holds a 20% equity stake. Quentin Inc.’s President is Benton Quentin, who is the only individual with significant management responsibility.
Quentin, Inc. would be required to identify one individual:
- Benton Quentin as the person with control
- No individuals as beneficial owners, because no sibling has a 25% or higher equity stake