Reasons for an unspecified interested party in beneficial ownership statements

[ScatteredInk]

Where a beneficial owner is confirmed not to exist (within the regulatory context of a given statement), we currently use an unspecified field in a beneficial ownership statement, with three possible reasons: "unknown", "noBeneficialOwners", "noNotifiableOwners".

Additionally, we say that where a beneficial owner is known to exist, but cannot be identified, a non-identifying person statement should be used.

The UK's PSC register has a broader set of reasons for information being unknown. These cover both the cases where there is no beneficial owner and where there is a beneficial owner but that person cannot, or should not, be identified.

I think we may want to move towards this model of retaining blank person statements but having more nuanced reasoning in the beneficial ownership statements so that:

• we can we see where the responsibility for missing information lies; and,
• when information is held back because of a disclosure exemption, we know whether this exemption applies to a natural person as an interested party or to a legal entity as the disclosing party. This is relevant for data protection.

These are the enumerations used in the Companies House API: missing data and exemptions.

My suggestion is that we extend reasons to:

reason	description
noBeneficialOwners	There are no beneficial owners who need to disclose ownership according to the rules under which this statement is made.
subjectUnableToConfirmOrIdentifyBeneficialOwner	The subject of this beneficial ownership statement has, as the disclosing party, been unwilling or unable to confirm the existence identify a beneficial owner.
interestedPartyHasNotProvidedInformation	The interested party in this beneficial ownership statement has not provided enough information to identify or confirm the identity of the beneficial owner.
subjectExemptFromDisclosure	The subject of this beneficial ownership statement is not required to disclose its beneficial owner. (Replaces noNotifiableOwners.)
interestedPartyExemptFromDisclosure	The interested party in this beneficial ownership statement is exempt from having their identity disclosed.
unknown	Unknown reason

[ScatteredInk]

We only have this in ownership-or-control statements, under subject\unspecified.

But several of these fields apply to anonymous/unknown entities and natural persons, which we model with entityStatements and personStatements, with the appropriate type - so some of these reasons will never get used.

I think we probably want to allow this block in both person and entity statements, in place of the current missingInfoReason.