Capitol Services’ Approach

Our Approach:

Capitol Services has been closely monitoring the new filing requirements and has met with FinCEN representatives to gain clarification and to provide our feedback.  Capitol Services is developing processes to securely receive and submit beneficial ownership reports on behalf of clients and looks forward to working with your firm to assist with the new filing requirements.

We recognize that there may be different interpretations of the definitions of the two types of company applicants.  When filing a beneficial ownership report for an entity we helped form, we will identify the Capitol Services employee who submitted the formation filing as the entity’s first company applicant. It will be up to the client to determine which party we should list as the entity’s second company applicant.