Question:  How much time will I have to spend if I do a “do-it-yourself” FinCEN report?

Answer:  The following text is from a Notice by the U.S. Treasury Department on 09/29/2023.

  • FinCEN estimates that 32,556,929 entities will submit initial beneficial owner information reports (“BOIRs”) in Year 1 (2024).  In Year 2 (2025) and beyond, FinCEN estimates that the number of initial BOIRs filed will be 4,998,468 per year.
  • FinCEN estimates the average burden of reporting BOI as 90 minutes per response for reporting companies with simple beneficial ownership structures (40 minutes to read the form and understand the requirement, 30 minutes to identify and collect information about beneficial owners and company applicants, and 20 minutes to fill out and file the report, including attaching an image of an acceptable identification document for each beneficial owner and company applicant).
  • FinCEN estimates the average burden of reporting BOI as 650 minutes per response for reporting companies with complex beneficial ownership structures (300 minutes to read the form and understand the requirement, 240 minutes to identify and collect information about beneficial owners and company applicants, and 110 minutes to fill out and file the report, including attaching an image of an acceptable identification document for each beneficial owner and company applicant).
  • FinCEN estimates the average cost of filing an initial BOIR per reporting company to be a range of $85.14 for entities with simple beneficial ownership to $2,614.87 for entities with complex beneficial ownership structures.

The table below is taken from a U.S. Treasury regulation.  It shows the U.S. Treasury’s estimates of the time and cost to prepare and file a FinCEN report.  Note the $1,350 cost for an entity with an intermediate structure and the $2,614 cost for an entity that has a complex structure.  Both of these costs greatly exceed our average fee to prepare and file a FinCEN report.

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