Beneficial Ownership Information Report

Things To Know Before You File

Don't Be Surprised By These Requirements

  1. The U.S. Treasury Department's BOI instructions define beneficial ownership in broad terms. Included in the definition are people not normally described as owners. Most beneficial owners, indeed, may not have a financial stake in the company. (For more info on this topic, see our FAQs page question, "Who is considered a beneficial owner?")
  2. BOI regulations require you to submit the following personal information for anyone who meets the government's definition of a "beneficial owner":
    • full legal name
    • date of birth
    • current residential address
    • personal identification information
    • a scanned copy of a current government photo ID (e.g., a driver's license or passport)
  3. You must file updated reports whenever any beneficial owner makes a name change, moves to a different address, or replaces the government ID used for prior BOI filings. In addition, certain internal changes can also trigger update requirements. With but few exceptions, updates are due within 30 days of the change.
  4. Updates are also necessary within 30 days whenever someone qualifies for the first time as a beneficial owner or when someone loses that status.
  5. Many CPA firms will not file BOI reports. Advice on how to comply with certain BOI requirements can border on offering legal counsel. In most jurisdictions, CPA's endanger their license if they venture into the practice of law.
  6. Anyone who fails to file or who submits incorrect information can face steep penalties administered by the Treasury Department's Financial Crimes Enforcement Network (FinCEN). These include:
    • Civil penalties of up to $500 per day starting January 2, 2025
    • Criminal fines of up to $10,000
    • Imprisonment for up to two years
  7. Consult the Treasury Department Financial Crimes Enforcement Network's BOI website for additional guidance.
  8. If you choose to submit the Beneficial Ownership Information reports on your own, be aware that the instruction manual is dozens of pages long and should be read carefully more than once. Guidance in the manual may be unclear at times regarding your specific situation. Allow plenty of time to complete your report.