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About Richard Keyt

Richard Keyt is an Arizona business law attorney who has formed 9,000+ LLCs and 400+ nonprofit corporations. He has 230 five star Google reviews. He is the founder of FinCEN Filer, LLC, and owns and operates https://corporatetransparencyact.net.
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If One Item in a FinCEN BOI Report Changes Must the Company File an Entirely New Report?

Question: If a reporting company needs to update one piece of information on a FinCEN BOI report, such as its legal name, does the reporting company have to fill out an entire new BOI report?

Answer: Updated BOI reports will require all fields to be submitted, including the updated pieces of information. For example, if a reporting company changes its legal name, the reporting company will need to file an updated BOI report to include the new legal name and the previously reported, unchanged information about [. . .]

What Events Require an Amended FinCEN BOI Report?

Question: What are some likely triggers for needing to update a beneficial ownership information report?

Answer: The following are some examples of the changes that would require an updated beneficial ownership information report:

  • Any change to the information reported for the reporting company, such as registering a new business name.
  • A change in beneficial owners, such as a new CEO, or a sale that changes who meets the ownership interest threshold of 25 percent.
  • Any change to a beneficial owner’s [. . .]

What Does a Reporting Company Do If Info in a Filed FinCEN BOI Report Changes?

Question: What should I do if previously reported information changes?

Answer: If there is any change to the required information about your company or its beneficial owners in a beneficial ownership information report that your company filed, your company must file an updated report no later than 30 days after the date of the change.  A reporting company is not required to file an updated report for any changes to previously reported information about a company applicant.

How Do I Get a Taxpayer Identification Number for a New Company?

Question:  How can I obtain a Taxpayer Identification Number (TIN) for a new company quickly so that I can file an initial beneficial ownership information report on time?

Answer: The Internal Revenue Service (IRS) offers a free online application for an Employer Identification Number (EIN), a type of TIN, which is provided immediately upon submission of the application. For more information on TINs, see “Taxpayer Identification Numbers (TIN)” at IRS.gov (https://www.irs.gov/individuals/international-taxpayers/taxpayer-identification-numbers-tin). For more information on Employer Identification Numbers and to access the EIN online application, [. . .]

What if Beneficial Owner or Applicant Does Not have a Permanent Residential Address?

Question: What residential address should be reported if a reporting company is required to report an individual’s residential address, but that individual does not have a permanent residential residence?

Answer: The residential address that is current at the time of filing should be reported to FinCEN. An updated report should be submitted within 30 calendar days if the address, or any other information previously reported, changes.

Can a Picture be Omitted on an ID Image for Religious Reasons?

Question: If a beneficial owner or company applicant’s acceptable identification document does not include a photograph for religious reasons, will FinCEN accept the identification document without the photograph?

Answer: Yes. If a beneficial owner or company applicant’s identification document does not include a photograph for religious reasons, the reporting company may nonetheless submit an image of that identification document when submitting its report, as long as the identification document is one of the types of identification accepted by FinCEN, such as a non-expired State-issued identification document.

Can a Reporting Company Have a P.O. Box?

Question: Can a reporting company report a P.O. box as its current address?

Answer: No. The reporting company address must be a U.S. street address and cannot be a P.O. box.

Must a FinCEN BOI Report be Filed Annually?

Question: Is there a requirement to annually report beneficial ownership information?

Answer: No. There is no annual reporting requirement. Reporting companies must file an initial BOI report and updated or corrected BOI reports as needed.

What are Acceptable Forms of Identification?

Question: What are some acceptable forms of identification that will meet the reporting requirement?

Answer: The only acceptable forms of identification are:

  1. A non-expired U.S. driver’s license (including any driver’s license issued by a commonwealth, territory, or possession of the United States);
  2. A non-expired identification document issued by a U.S. state or local government, or Indian Tribe;
  3. A non-expired passport issued by the U.S. government; or
  4. A non-expired passport issued by a foreign government (only when an individual [. . .]

What Applicant Info is Disclosed in a FinCEN BOI Report?

Question: What information will a reporting company have to report about its company applicants?

Answer: For each individual who is a company applicant, a reporting company will have to provide:

  1. The individual’s name;
  2. Date of birth;
  3. Address; and
  4. An identifying number from an acceptable identification document such as a passport or U.S. driver’s license, and the name of the issuing state or jurisdiction of the identification document.

The reporting company will also have to report an image of the identification document used to [. . .]

What Beneficial Owner Info is Disclosed in a FinCEN BOI Report?

Question:  What information will a reporting company have to report about its beneficial owners in its FinCEN BOI report?

Answer: For each individual who is a beneficial owner, a reporting company will have to provide:

  1. The individual’s name;
  2. Date of birth;
  3. Residential address; and
  4. An identifying number from an acceptable identification document such as a passport or U.S. driver’s license, and the name of the issuing state or jurisdiction of the identification document (for examples of acceptable identification, see Question F.5).

The reporting [. . .]

What Reporting Company Info is Disclosed in Its FinCEN BOI Report?

Question: What information will a reporting company have to report about itself in its FinCEN BOI report?

Answer: A reporting company will have to report:

  1. Its legal name;
  2. Any trade names, “doing business as” (d/b/a), or “trading as” (t/a) names;
  3. The current street address of its principal place of business if that address is in the United States (for example, a U.S. reporting company’s headquarters), or, for reporting companies whose principal place of business is outside the United States, the current address from [. . .]

What Causes an Individual to Become a Company Applicant?

Question: The company applicants of a reporting company include the individual “primarily responsible for directing the filing of the creation or registration document.” What makes an individual “primarily responsible” for directing the filing?

Answer:  At most, two individuals need to be reported as company applicants:

  1. the person who directly files the document with a secretary of state or similar office, and
  2. if more than one person is involved in the filing of the document, the person who is primarily responsible for directing or controlling [. . .]

Who are Beneficial Owners When Ownership is in Dispute?

Question: What should a reporting company report if its ownership is in dispute?

Answer:  If ownership of a reporting company is the subject of active litigation and an initial FinCEN BOI report has not been filed, a person authorized by the company to file its beneficial ownership information should comply with the requirements by reporting:

  • all individuals who exercise substantial control over the company, and
  • all individuals who own or control, or have a claim to ownership or control of, at least 25 percent [. . .]
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