New Federal Reporting Requirement for Beneficial Ownership Information (BOI)

Effective January 1, 2024, many companies in the United States must report
information about their beneficial owners—the individuals who ultimately own or
control the company—to the Financial Crimes Enforcement Network (FinCEN), a
bureau of the U.S. Department of the Treasury.

Beneficial ownership informationreporting is not an annual requirement. Unless a company needs to update or correct
information, a report only needs to be submitted once.

Be sure to review FinCEN’s Small Entity Compliance Guide, which provides
information to help small businesses comply with this reporting requirement.
Who Has to Report?
Companies required to report are called reporting companies. Reporting companies
may have to obtain information from their beneficial owners and report that
information to FinCEN.

Your company may need to report information about its beneficial
owners if it is:
1. a corporation, a limited liability company (LLC), or was otherwise
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.

Who Does Not Have to Report?
Twenty-three types of entities are exempt from beneficial ownership information
reporting requirements, including publicly traded companies, nonprofits, and certain
large operating companies.

FinCEN’s Small Entity Compliance Guide includes checklists for
each of the 23 exemptions that may help determine whether
your company qualifies for an exemption. Please review Chapter 1.2
of the Guide for more information.

How Do I Report?
Reporting companies report beneficial ownership information electronically through
FinCEN’s website: www.fincen.gov/boi. The system provides a confirmation of receipt
once a completed report is filed with FinCEN.

When Do I Report?
FinCEN began accepting reports on January 1, 2024.
• If your company was created or registered prior to January 1, 2024, you will have
until January 1, 2025 to report BOI.
• If your company is created or registered in 2024, you must report BOI within 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 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 30 days