Accumera is staying on top of the Corporate Transparency Act (CTA) updates put forth by the Financial Crimes Enforcement Network (FinCEN) regarding the upcoming requirements and timeline for companies to begin reporting their Beneficial Owner Information (BOI) that takes effect in January of 2024.
Where do I go to Report?
Currently FinCEN is still in the process of creating its Database and to collect the information, store it and keep it secure. Once finished, companies will be able to meet their reporting requirements electronically through this secure filing system via its own website.
What should I do while waiting for the system to be completed?
We strongly suggest that companies start looking into if they are exempt (More details on exemptions), and if not start gathering the data and resources they will be required to report. It should be noted that companies that do qualify as exempt may still need to file an initial report claiming their exempt status.
If my company is not exempt, what do I need to file?
If your company is required to report their BOI, you should identify who the beneficial owners of the company(s) are and gather information. You will need to provide information such as their names, birthdates, Address, and a unique identifying number from an acceptable identification document, such as a non-expired passport, government-issued ID document, or driver’s license. (They will also be required to provide an image of the document that contains that unique identifying number and a photo of the individual.)
Is there anything else I need to report besides my company’s BOI?
FinCen identifies two types of entities that must report, “existing entities” and “new entities”. Existing entities will only have to report beneficial ownership information. New entities, however, will have to report the BOI for their companies as well as that of the “company applicants”. FinCEN defines a company applicant as “the individual who files the document that forms the entity. In the case of a foreign reporting company, a company applicant would be the individual who files the document that first registers the entity to do business in the United States.” (read further on company applicants here)
Companies will want to develop internal guidelines for updating their BOI as is needed, as it is their responsibility to update FinCEN on those changes.
Can Accumera help me file the BOI Information?
We will continue to keep on top of the updates from FinCEN and the progress they are making with the reporting system. We are here to play a key role in assisting our clients and keeping them compliant with the requirements. Accumera will be ready to assist with the reporting for both existing companies and new entity’s that we form for our clients.