Activating BOI Reporting in Entities

Background

On Monday, January 1, 2024, US Financial Crimes and Enforcement Network (FinCEN) implemented the Corporate Transparency Act (CTA). Beneficial Ownership Information Reporting (BOIR) is enforced as part of the new CTA regulations.

To learn more about Beneficial Ownership Information Reporting, refer to the FinCEN website.

To learn more about reporting requirements and exemptions, refer to the FinCEN compliance guide.

BOIR e-filing licence in Diligent Entities

BOIR e-data recording and e-filing can be purchased as an additional licence option for Diligent Entities.

This functionality comes with additional user role rights controlling levels of access.

Process overview

Before you can report Beneficial Ownership Information through Entities, complete the following tasks.

  1. Gather information on Reporting Companies.

  2. Obtain BOIR electronic filing licence.

  3. Obtain API e-filing access to FinCEN and configure e-filing accounts.

  4. Configure user access to BOIR e-filing.

1. Gather information on Reporting Companies

  1. Determine which companies are required to report Beneficial Ownership Information. For detailed instructions and requirements, refer to the FinCEN compliance guide.

    Note

    If the requirements are unclear or there are possible exemptions applying to reporting companies, seek legal guidance and advice.

  2. For the applicable Reporting Companies, gather data as specified in the FinCEN compliance guide.

2. Obtain BOIR electronic filing licence

Beneficial Ownership Information Reporting in Entities is an opt-in feature and requires a licence.

To verify if you're licenced to use this functionality, go to System Tools > Licence > Feature Codes and verify if the BOIR Electronic filing option is active.

If you do not have the licence to use BOIR Electronic filing and you require access, contact your Customer Success Manager.

3. Obtain API e-filing access to FinCEN and configure e-filing accounts

Before you can report Beneficial Ownership Information through Entities, you must complete the following tasks.

  1. Apply for an API e-filing account to FinCEN.

    For information on how to apply, refer to the FinCEN website and use the System-to-System API option.

    Note

    This process can take up to 6 weeks.

  2. When FinCEN provisions you with the accounts, you receive a Client ID and a Client Secret you will use as username and password for test filing and live filing to the FinCEN portal.

  3. Entities Administrator provisions e-filing accounts.

    An administrator in Entities records your Client ID and Client Secret in the e-filing profile used for BOIR e-filing.

    In System Tools > List Manager > Electronic Filing Profiles, the following profiles must be updated:

    • US BOI API Filing (EFBOI)

    • US Test BOI API Filing (EFBOITEST)

4. Configure user access to BOIR e-filing

Your Entities administrator must configure the new user role rights for accessing the BOIR e-filing functionality. These user role rights are inactive by default and must be configured by an administrator.

Accessing BOIR data

The following user access levels are available in Entities:

  • No access – This option is active for all users by default

  • View BOIR Details Read-only access

  • Add/Edit BOIR Details Standard access

To access and update the new user role rights, go to Company Security > Beneficial Ownership Information Report (US).

Submitting data to FinCEN

The new Electronic Filing (US BOI) FinCEN (Standard) user role right controls who can submit the data electronically to FinCEN.

To edit this user role right, go to Electronic Filing and select or deselect the Electronic Filing (US BOI) FinCEN (Standard) option.

Viewing FinCEN ID

Use the View FinCEN Id (Read Only) user role right to control access over who can view this data.

To edit this user role right, go to Company Security > Company Views and Windows.

Editing FinCEN ID

Use the Edit FinCEN Id (Standard) user role right to control access over who can edit this data.

To edit this user role right, go to Company Security > Company Wizards.