Latest Updates
December 26, 2024: A Fifth Circuit panel vacated previous orders, temporarily suspending BOI enforcement. Voluntary filing remains available.
December 24, 2025: Fifth Circuit reinstated BOI reporting requirements.
December 3, 2024: Eastern District of Texas issued nationwide preliminary injunction halting BOI mandates.
BOI Reporting Essentials
The Beneficial Ownership Information (BOI) rule under the Corporate Transparency Act (CTA) became effective January 1, 2024. Key deadlines:
- Pre-2024 entities: File by January 1, 2025
- 2024 entities: File within 90 days of formation
- Post-2025 entities: File within 30 days
Non-compliance penalties:
- $500 daily fine (max $10,000)
- 2 years imprisonment
BOI identifies individuals who directly/indirectly own/control ≥25% of a company or exercise substantial control. Required details include:
- Full legal name
- Date of birth
- Current residential address
- Government-issued ID number
Reporting Requirements
Covered Entities
- Domestic Reporting Companies: Corporations/LLCs formed through state filings
- Foreign Reporting Companies: Foreign entities registered to do business in the US
Exemptions (23 Categories)
| Exemption | Entity Type |
|---|
| 1 | SEC-registered issuers |
| 2 | Governmental authorities |
| 3 | Banks/credit unions |
| … | … (full list maintained by FinCEN) |
FinCEN Compliance Flowchart →
Filing Process
Methods
- Online Portal: https://boiefiling.fincen.gov/boir/html
- PDF Submission: Requires Adobe Reader
- API Integration: For automated systems
Key Steps
- Determine report type (Initial/Update/Correction)
- Obtain FinCEN ID (optional for multi-entity management)
- Submit company details and beneficiary information
Compliance Strategy
- Self-Filing: Use FinCEN’s multilingual guides
- Professional Services: CPA/attorney assistance available
- Recordkeeping: Maintain updated ownership records
Resources