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Beneficial ownership docs are not "lawyer will handle it"

Beneficial ownership docs are not "lawyer will handle it"

Corporate buyer through a Mississauga numbered company. Agent checks a FINTRAC box on a form. Nobody collects an ownership register until the lawyer emails the day before closing.

Direct answer

For entity clients, plan to obtain beneficial ownership information, take reasonable measures to confirm accuracy, and keep records — per FINTRAC expectations for real estate brokers and sales representatives. Put supporting documents on checklist lines early. “Lawyer will handle FINTRAC” does not make the brokerage file complete.

This is general information, not legal or AML advice.

Beneficial ownership in plain language

IdeaPractical meaning
Beneficial owners are individualsAnother corporation is not the end of the chain
Control threshold (common framing)Individuals who directly or indirectly own or control 25% or more of shares (or equivalent for other entity types), plus certain trust roles — confirm current FINTRAC wording
Your jobCollect, confirm accuracy with reasonable measures, record-keep — per your AML program
Not your software’s jobHivi-X does not calculate ownership percentages or file FINTRAC reports

Typical supporting documents (illustrative)

Entity typeDocuments teams often request
CorporationArticles/formation, shareholder register or ownership chart, signing authority, ID for beneficial owners and signatories
TrustTrust extracts your policy allows, trustee/beneficiary ID as required
PartnershipAgreement excerpts, partner ID
Complex structuresLayered charts — escalate to compliance early

Exact requirements change with guidance updates and risk rating. Follow the brokerage AML manual — not a blog checklist.

Workflow that survives closing week

  1. Entity template at offer — not a generic residential ID list alone.
  2. Scoped upload to the authorized contact.
  3. QC — company name on offer vs formation docs; reject unreadable scans.
  4. Compliance review when ownership stories conflict.
  5. Export into the deal/brokerage archive with retention your program requires.

Related internal guides: brokerage compliance records, FINTRAC client ID verification records, receipt of funds record-keeping.

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General information only. Not legal, real estate, or AML advice. Hivi-X is document-collection software — not a licensed real estate brokerage and not a FINTRAC filing tool. Not affiliated with or endorsed by RECO, TRREB, or FINTRAC. Verify current FINTRAC obligations with your brokerage compliance officer and counsel.

Answers are general operational information only — not legal, tax, regulatory, clinical, privacy, immigration, or professional advice. Requirements vary by matter, client, and regulator.

Frequently asked questions

Is this legal advice?
No. FINTRAC guidance and your brokerage AML program define exact triggers, forms, and retention. Confirm with compliance and counsel.
Who counts as a beneficial owner?
In FINTRAC framing, beneficial owners are individuals — not another corporation — who own or control the entity, commonly including those who directly or indirectly own or control 25% or more of shares (or equivalent for other entities), plus certain trust roles. Verify current FINTRAC definitions for your case.
What supporting documents do teams usually collect?
Often articles or formation records, ownership registers or charts, authorized-signatory ID, and ID for identified beneficial owners — plus whatever your brokerage checklist requires. Exact packs vary by entity type.
When should collection start?
When you know the buyer or seller is an entity — typically at or soon after offer — not the week before closing.
Does Hivi-X determine beneficial owners?
No. Staff collect and QC documents; ownership determination and FINTRAC reporting remain brokerage compliance processes.

Collect complete client documents without the chase

hivi-x helps Ontario realtors and teams request ID, income proof, references, consent, and forms in one secure Canadian-hosted workflow — with reusable checklists, client uploads, missing-item tracking, AI summaries, and PDF package export.

FINTRAC Beneficial Ownership Real Estate | hivi-x Docs