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.