Deadline Looming: Beneficial Ownership Information (BOI)

Requirements

The law requires Federal reporting of Beneficial Ownership Information (BOI) for all state-registered entities. A beneficial owner is someone who:

• Owns 25% or more of a company’s interest
• Exercises substantial control over a company
• Receives substantial economic benefits from a company’s assets

For detailed instructions on how to complete a BOI declaration through the FinCEN website, please, WATCH THIS VIDEO.

It is extremely important that these filings are completed by the end of the year.

Deadlines

• Entities formed before 2024: Initial report by January 1, 2025.
• Entities formed after January 1, 2025: Initial report within 30 days.
• If there’s a change in beneficial owners, an update report is due within 30 days of the changes.

Penalties

• Starting at $500 per day after the due date
• Maximum penalty per entity of $10,000 (note: multiple entities, would mean multiple $10k fines)

For an individual needing to make multiple BOI declarations, it is encouraged to create a FinCEN ID. This ID creates a unique FinCEN reporting number that can be used to streamline the process.

Your Action Steps

• Identify entities needing reporting.
  • Generally, all Secretary of State registered entities will need to complete a filing
  • But there are 23 defined entity types exempt from reporting: LIST OF EXEMPT ENTITIES (on pg. 4)
• Determine who are the beneficial owners – use the three bullet points above for reference
• Gather beneficial ownership information or FinCEN IDs: you will need either drivers’ licenses, or FinCEN IDs
• Complete BOI filings via the FinCEN website:
  • OBTAIN FinCEN ID
  • COMPLETE BOI FILINGS

Need Additional Help?

Please reach out to your engagement manager if you have questions or need guidance to remain compliant.