How often do I need to update my BOI report?
Entities are required to update their Beneficial Ownership Information (BOI) reports to ensure that the information remains accurate and current. The frequency of updates depends on changes in the beneficial ownership information. Specifically, updates are required in the following circumstances:
Changes in Beneficial Owners:
If there are changes in the individuals who qualify as beneficial owners, such as when a new owner acquires an interest in the entity or an existing owner transfers their interest, the BOI report must be updated.
Examples include the addition of a new beneficial owner, the departure of a current owner, or a change in the ownership percentage of an existing owner.
Changes in Personal Information of Beneficial Owners:
If there are changes in the personal information of beneficial owners, such as a change in name, address, or identification number, the BOI report must be updated.
This includes updates to reflect changes in residential or business addresses, legal name changes due to marriage or other reasons, and updates to identification documents if they expire or are replaced.
Changes in Control or Management:
If there are changes in the control or management of the entity that affect who has substantial control, the BOI report must be updated.
This includes changes in senior officers, directors, or any other individuals who exercise significant control over the entity’s operations and decisions.
Reporting Deadlines:
30-Day Update Requirement: Entities must update their BOI report within 30 days of any change in beneficial ownership information. This ensures that the information on file with FinCEN is always accurate and up-to-date.
Annual Review and Confirmation: While not explicitly required by FinCEN, it is good practice for entities to conduct an annual review of their beneficial ownership information and confirm that all details remain accurate. This can help identify any changes that may have been overlooked and ensure compliance with reporting requirements.
Examples of Situations Requiring Updates:
A new shareholder acquires a 25% ownership stake in the entity.
An existing beneficial owner sells their interest and is no longer associated with the entity.
A beneficial owner changes their residential address or obtains a new identification document.
The entity appoints a new CEO or other senior officer who exercises substantial control over the entity.
Penalties for Failure to Update: Failure to timely update the BOI report can result in significant penalties, including fines and legal action. Ensuring that updates are made within the required timeframe is crucial to maintain compliance and avoid these consequences.
Our Services for Ongoing Compliance: Our firm offers ongoing compliance services to help you manage updates to your BOI report. We provide:
Regular Monitoring: Monitoring of any changes in beneficial ownership information.
Timely Updates: Prompt updates to the BOI report within the required 30-day timeframe.
Annual Reviews: Annual reviews of beneficial ownership information to ensure accuracy and compliance.
By leveraging our expertise, you can ensure that your BOI reports are always up-to-date and in compliance with FinCEN regulations.