PPL CPA will not be responsible for advising you regarding the legal or regulatory aspects of your company’s compliance with the CTA, nor are we responsible for the preparation or submission of beneficial ownership information reports to FinCEN.
Like initial BOI reports, updated or corrected BOI reports should be filed electronically through the secure filing system at the Financial Crimes Enforcement Network.
Is there a requirement to annually report beneficial ownership information?
No. There is no annual reporting requirement. Reporting companies must file an initial BOI report and “updated or corrected” reports as needed.
What if there are changes to or inaccuracies in reported information?
In addition to filing an initial BOI report, reporting companies must also update and correct information in their previously filed BOI reports. Individuals who obtain FinCEN identifiers must also update, and correct information previously reported to FinCEN. Your company must file an updated BOI report no later than 30 days after the date on which the change occurred.
The following are some examples of changes that would require an updated BOI report:
Any change to a beneficial owner’s name, address, or unique identifying number provided in a BOI report. Note: If a beneficial owner obtained a new driver’s license or other identifying document that includes the changed name, address, or identifying number, the reporting company also would have to file an updated beneficial ownership information report with FinCEN, including an image of the new identifying document.
- Any change to the information reported for the reporting company, such as registering a new DBA.
- A change in beneficial owners, such as a new Chief Executive Officer, a sale that changes who meets the ownership interest threshold of 25 percent, or the death of a beneficial owner. Note: When a beneficial owner dies, resulting in changes to the reporting company’s beneficial owners, report those changes within 30 days of when the deceased beneficial owner’s estate is settled. The updated report should, to the extent appropriate, identify any new beneficial owners.
Special rule: Keep in mind the update requirement related to the special reporting rule for a minor child. When a beneficial owner that was a minor child reaches the age of majority, you must file an updated BOI report.
Note: There is no requirement to report a company’s termination or dissolution.
Does a reporting company need to file a beneficial ownership information report each time it registers to do business in a different state?
No. A reporting company does not need to file additional BOI reports in connection with subsequent filings with secretaries of state or similar offices.
Existing Entities: Due by January 1,2025
New entities created or registered in 2024: Due 90 days after filing
New entities created or registered in 2025: Due 30 days after filing