FinCEN Updates Beneficial Ownership Information Reporting FAQs

In January 2024, the Financial Crimes Enforcement Network (FinCEN) updated its frequently asked questions on the Beneficial Ownership Information (BOI) Reporting requirements.

In 2021, Congress passed the Corporate Transparency Act (CTA). The CTA requires many entities doing business in the US to report information about the individuals who ultimately own or control them (the entity’s “beneficial owners”). BOI reporting is not an annual requirement. Entities only need to submit reports once, unless the reported information needs to be updated or corrected.

Entities that are required to comply with the CTA (“reporting companies”) must file their initial reports by the following deadlines:

  • Reporting companies created or registered to do business in the US before January 1, 2024, must file their BOI reports by January 1, 2025.
  • Reporting companies created or registered to do business in the US in 2024 have 90 calendar days after receiving notice of the entity’s creation or registration is effective to file their BOI reports.

Beneficial ownership information reporting FAQs. To help reporting companies to comply with the BOI reporting requirements, FinCEN created some frequently asked questions.

In January 2024, FinCEN added 15 new FAQs covering the following topics:

  • General questions about the BOI reporting requirements
  • The BOI reporting process
  • What is a reporting company
  • Who is a beneficial owner
  • Who is a company applicant
  • The BOI reporting requirements
  • Filing initial BOI reports
  • Who doesn’t have to report BOI (reporting company exemptions)
  • FinCEN identifiers, and
  • Third-party service providers

These reporting rules may require legal counsel assistance.

For more information about the BOI reporting process, visit https://www.fincen.gov/boi.