FinCEN notes that “as a general matter, small local community organizations, such as Scout Troops and youth sports leagues, are unincorporated associations rather than legal entities and therefore not subject to the beneficial ownership requirement.â€
Clarification is need for the following example:
A local Girl Scout troop wanting to establish an account – if the NYDOS website search of “Girl Scouts of Nassau Countyâ€, indicates a domestic not-for-profit corporation and an account is established at the local troop level, with the only reference to the corporation being use of the EIN. Does BO apply? If so, would the requirement be to collect for the control prong only?