New Federal Reporting Information

The New Federal Reporting Requirement for Beneficial Ownership Information (BOI) became effective on January 1, 2024. Many companies in the United States must report information about their beneficial owners – the individuals who own or control the company. This information must be provided to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.

  • This Beneficial Ownership Information need only be submitted once, unless the company needs to update or make corrections.
  • There are no fees associated with filing the Beneficial Ownership Information.
  • Failure to meet the reporting deadlines may result in fines of up to $500.00 a day.

Who Has to Report?

Companies required to report are called reporting companies. Reporting companies must provide information from their owners and report it to FinCEN. Your company may need to report information about its owners if it is:

1. A Corporation (B, C, S, etc.), a Limited Liability Company (LLC), or a company that was created in the United States by filing a document with a Secretary of State or any similar office under the law of a state or Indian tribe; or

2. A foreign company and was registered to do business in any U.S. state or Indian tribe by such a filing.

When Do I Report?

  • If your company was created or registered prior to January 1, 2024, you will have until January 1, 2025 to report your BOI.
  • If your company was created or registered in 2024, you must report BOI within ninety (90) calendar days after receiving actual or public notice that your company’s creation or registration is effective, whichever is earlier.
  • If your company is created or registered on or after January 1, 2025, you must file BOI within thirty (30) calendar days after receiving actual or public notice that its creation or registration is effective.
  • Any updates or corrections to beneficial ownership information that you previously filed with FinCEN must be submitted within thirty (30) days.

Do Sole Proprietorships Need to Report BOI?

No, unless a sole proprietorship was created (or, if a foreign sole proprietorship, registered to do business) in the United States by filing a document with a Secretary of State or similar office. An entity is a BOI reporting company only if it was created (or, if a foreign company, registered to do business) in the United States by filing such a document. If you filed a document with a government agency to obtain:

1.     An IRS employer identification number,

2.     A fictitious business name (DBA), or

3.     A Professional or Occupational license you are not considered a reporting entity, and therefore a sole proprietorship will not need to file a BOI.

NANP suggests that members review FinCEN’s Small Entity Compliance Guide, Beneficial Ownership Information Reporting Requirements, which provides information to help small businesses comply with this reporting requirement.

To File your company BOI use the following link: Financial Crimes Enforcement Network, Beneficial Ownership Information Filing

Members should direct questions about their company structure and reporting their Beneficial Ownership Information to their Accountant/Certified Public Accountant (CPA), or contact a FinCEN representative through their website.

Laura Waldo

NANP Legislative Affairs Specialist

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