Effective January 1, 2024, many companies doing business in the United States will have to file a beneficial ownership information (BOI) report with the Financial Crimes Enforcement Network (FinCEN), an agency under the U.S. Treasury Department. The BOI report is designed to collect information about the individuals who own or control companies operating in the U.S.

Beneficial Ownership Information Reporting

A Quick Guide to Understanding the New Compliance Requirement Under the Corporate Transparency Act

Is Your Entity Considered a Reporting Company?

Many domestic and foreign business entities fall under the “reporting company” definition. Does either of the following descriptions fit your business?

Domestic reporting company – A Limited Liability Company (LLC), Corporation, or other entity formed or created by filing a document with a secretary of state (or similar office) under the laws of a U.S. state or Indian tribe.
Foreign reporting company – An entity formed or created under the laws of a foreign country that has filed a document with the secretary of state (or similar office) to register to do business in any U.S. state or Indian tribal territory.

If yes, and your entity doesn’t qualify for an exemption from the reporting requirement, then your company must file a B0I report. (See https://www.fincen.gov/boi for a full list of all 23 exemptions.)

If no, your entity likely does not have to file a B0I report because it does not meet the reporting company’s definition.

Reporting Deadlines

When a beneficial ownership information report is due depends on when the reporting company was created or registered.

Reporting companies created or registered to do business before January 1, 2024 – Initial BOI report is due by January 1, 2025.
Reporting companies created or registered on or after January 1, 2024, and before January 1, 2025: The Initial BOI report is due within 90 days of the entity’s formation.
Reporting companies created or registered on or after January 1, 2025 – Initial BOI report is due within 30 days of the entity’s formation.

BOI reports are not a recurring requirement. However, a reporting company must file an updated report within 30 calendar days of any changes to the information about the entity or its beneficial owners.

What Information Does a BOI Report Require?

Reporting Company Information

Full legal name.
Any DBAs, fictitious names, or trade names used to conduct business
Principal U.S. business address.
Formation jurisdiction (state, tribal, or foreign) of a domestic entity or a foreign entity’s first registered jurisdiction in the U.S.
IRS taxpayer ID number (TIN), including an EIN. (If a foreign reporting company doesn’t have a TIN from the IRS, it may use a tax ID issued by a foreign jurisdiction and must provide the name of that jurisdiction.)

Beneficial Owner Information

Full legal name.
Date of birth.
Complete residential street address.
Personal identification number and issuing jurisdiction from a non-expired U.S. passport, state driver’s license, or other ID document issued by a state, local government, or tribe. They must also provide an image of their ID document.

Company Applicant Information*

Full legal name.
Date of birth.
Complete residential street address. (If a company applicant forms or registers a company in the course of conducting their business, i.e., a paralegal, they should use their business street address instead.)
Personal identification number and issuing jurisdiction from a non-expired U.S. passport, state driver’s license, or other ID document issued by a state, local government, or tribe. They must also provide an image of their ID document.

*Only required for domestic and foreign reporting companies created or first registered on or after January 1, 2024.

About FinCEN Identifiers

A FinCEN identifier is a unique number assigned upon request to a reporting company or individual. To obtain a FinCEN identifier, the applicant must provide all required information. FinCEN identifiers are optional; no one is required to obtain one. After receiving a FinCEN ID number, that identifier may be used instead of entering certain information about beneficial owners and company applicants into the BOI report.

Need Help?

Consider consulting an attorney, accountant, or financial/business advisor to determine if your company must file a BOI report and identify your beneficial owners and company applicants. Visit https://www.fincen.gov/boi for the latest information about beneficial ownership information reporting requirements.

HireEﬀect’s filing specialists are ready to help you prepare and submit your company’s beneficial ownership information report.

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