Beneficial Ownership Information (BOI) Reporting

Beneficial Ownership Information (BOI) Reporting is a requirement for many companies to report information about the individuals who ultimately own or control them. This reporting is done to comply with the Corporate Transparency Act. Keep reading to find out if you are required to file this report.

Beginning on January 1, 2024, many companies in the United States will have to report information about their beneficial owners, i.e., the individuals who ultimately own or control the company. They will have to report the information to the Financial Crimes Enforcement Network (FinCEN). FinCEN is a bureau of the U.S. Department of the Treasury.

Who Must File? Companies falling under the reporting requirements must file a BOI report. These reports identify two categories of individuals:

• Beneficial Owners: These are the individuals who directly or indirectly own or control the company.

• Company Applicants: These are the individuals associated with the company’s application. Only reporting companies created or registered on or after January 1, 2024, will need to report their company applicants.

1. What Information Is Reported? The report includes identifying information about the beneficial owners and company applicants. A reporting company will have to report:

   1. Its legal name;

   2. Any trade names, “doing business as” (d/b/a), or “trading as” (t/a) names;

   3. The current street address of its principal place of business if that address is in the United States (for example, a U.S. reporting company’s headquarters), or, for reporting companies whose principal place of business is outside the United States, the current address from which the company conducts business in the United States (for example, a foreign reporting company’s U.S. headquarters);

   4. Its jurisdiction of formation or registration; and

   5. Its Taxpayer Identification Number (or, if a foreign reporting company has not been issued a TIN, a tax identification number issued by a foreign jurisdiction and the name of the jurisdiction).

   A reporting company will also have to indicate whether it is filing an initial report, or a correction or an update of a prior report.

   
   

2. When to File? The reporting deadlines began on January 1, 2024. If you’re subject to these requirements, make sure to file your report in a timely manner:

• A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025, to file its initial BOI report.

• A reporting company created or registered in 2024 will have 90 calendar days to file after receiving actual or public notice that its creation or registration is effective.

• A reporting company created or registered on or after January 1, 2025, will have 30 calendar days to file after receiving actual or public notice that its creation or registration is effective.

FinCEN launched the BOI E-Filing website for reporting beneficial ownership information (https://boiefiling.fincen.gov) on January 1, 2024.

Alert: FinCEN has learned of fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act.

These fraudulent scams may include:

• Correspondence requesting payment. There is NO fee to file BOI directly with FinCEN. FinCEN does NOT send correspondence requesting payment to file BOI. Do not send money in response to any mailing that claims to be from FinCEN or another government agency.

• Correspondence that asks the recipient to click on a URL or to scan a QR code. Those e-mails or letters are fraudulent. Do not click any suspicious links or attachments or scan any QR codes in emails, on websites, or in any unsolicited mailings.

• Correspondence that references a “Form 4022,” or an “Important Compliance Notice.” This correspondence is fraudulent. FinCEN does not have a “Form 4022.” Do not send BOI to anyone by completing these forms.

• Correspondence or other documents referencing a “US Business Regulations Dept.” This correspondence is fraudulent; there is no government entity by this name.+