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of <h1>Company shareholding by non-individual members (10%+) triggers BEN-1 SBO declarations and section 90(5) BEN-4 notices compliance.</h1> Every reporting company must take necessary steps to determine whether any individual qualifies as a significant beneficial owner in relation to the company, identify such individual, and require that individual to submit a declaration in Form BEN-1; this imposes an affirmative compliance obligation to obtain and document SBO disclosures. Where any member other than an individual holds not less than 10% of the company's shares, voting rights, or right to receive or participate in dividend or other distribution in a financial year, the company must issue a notice to that member seeking information under section 90(5) in Form BEN-4; this compels the member to furnish SBO-related information and enables statutory tracing of beneficial ownership through non-individual members.
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