Earlier this year, we informed you about the Financial Crimes Enforcement Network (FinCEN) Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act. As the deadline approaches, we want to remind you of key details and provide updates to ensure your compliance.

On October 3, 2024, FinCEN released updated Frequently Asked Questions (FAQs) to address common inquiries regarding the BOI Reporting Rule. These FAQs offer further guidance regarding filing requirements and processes for reporting beneficial ownership information.

Filing Requirements and Updated Deadlines 

(as of December 25, 2024):

• Reporting companies created or registered prior to January 1, 2024: new reporting deadline of January 13, 2025 (would otherwise have been required to report by January 1, 2025).

• Reporting companies created or registered in the U.S. on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024: new reporting deadline of January 13, 2025.
• Reporting companies created or registered in the U.S. on or after December 3, 2024, and on or before December 23, 2024: reporting deadline extended an additional 21 days from their original filing deadline.
• Reporting companies created or registered in the U.S. on or after January 1, 2025: reporting deadline is 30 days after receiving actual or public notice that their creation or registration is effective.
  
  

FinCEN is Now Accepting Reports:

FinCEN has launched its online portal for submitting BOI reports. Companies can now file their reports electronically or download a printable form. You can access the portal and begin your filing here.

Information Required for Reporting:

To comply with BOI reporting requirements, you must provide several pieces of key information for both the corporate entity and any beneficial owners, including:

• Company and beneficial owner addresses
• Tax identification numbers
• Corporate registration details
• Identification documentation for beneficial owners (e.g., passports, driver’s licenses)

Next Steps:

If your company is required to report, we strongly recommend gathering the necessary information promptly to meet the deadlines.

The Corporate and Business Services attorneys at Mansour Gavin are ready to assist with any questions or concerns you may have regarding these mandatory filings. Please don't hesitate to contact us for guidance on completing your report and ensuring compliance.