For purposes of the BOI rule, a “beneficial owner” is any
individual
who, directly or indirectly,exercises
substantial control
over a reporting company
or
owns or controls at least
25% of theownership interests
of a reporting company. Note that even though the rule refers to these individuals as beneficial
owners
, many individuals who are considered beneficial owners under theBOI rule are likely to have no material ownership interest at all, but they will need to be identified as beneficial owners by virtue of exercising substantial control.