Reporting BOI Information to FinCEN

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 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 access levels.

To learn more about setting up access to BOI reporting in Entities, refer to Activating BOI Reporting in Entities.

Process overview

To e-file BOIR data to FinCEN, complete the following steps.

  1. Gather company data.

  2. Prepare data for e-filing.

  3. Verify your documents.

  4. E-file documents to FinCEN.

1. Gather company data

Record the Reporting Company data with the Set-up BOI Reporting (US) wizard before e-filing it to FinCEN.

The wizard guides you through the sections required by FinCEN so that you can create an initial report, correct or update an existing report, or report a recent exemption.

To access the wizard, in Company details, go to Wizards > Set-up BOI Reporting (US).

To learn more about how Entities stores BOIR data, refer to US Beneficial Ownership Information Reporting (BOIR) in Entities.

Reporting the Current US Address

Depending on the company's office address, the following data will be used as Current US Address:

  • For domestic US companies, Main Office Address will be used.

  • For US non-state US territories, such as Puerto Rico, you need to add the country to the list of main office addresses manually.

  • For foreign companies, Registered Office Address will be used.

For all companies, you can use a different address as Current US Address by listing it in Alternate BOIR Address.

Add the country to the list of main office addresses

  1. Go to System Tools > List Manager > Address Types (All).

  2. Open the MAINOFFICE address type and add the required information.

Listing Company Applicants

Company Applicants are only required if the Reporting Company was created on or after January 1, 2024. You must list at least one and a maximum two applicants

2. Prepare data for e-filing

After you record the Reporting Company data, you can prepare it for e-filing it using the BOI Filing (US) wizard.

  1. To access the wizard, in Company details, go to Wizards > BOI Filing (US).

  2. Complete these screens to prepare data:

    • Filing Information

    • BOIR Person to File

    • Authorise Submission

    • Action

    • Notes

3. Verify your documents

Use the verification step in the BOI Filing (US) wizard to check the completeness of your submission before you process to e-filing.

  1. In the BOI Filing (US) wizard, proceed to the Documents screen.

  2. In the table, select the documents to verify and select Next.

    When the process is complete, the table displays the Completed status and the documents are displayed as clickable links.

  3. To verify a document, select its link to open the viewing options. Select the output from the dropdown menu and go to View.

    The document opens with the report. Items requiring updates are shown in red text.

4. E-file documents to FinCEN

When you're ready to submit the documentation to FinCEN, you can e-file BOIR using the BOI Filing (US) wizard.

  1. In the BOI Filing (US) wizard, proceed to the Documents screen.

  2. Verify the selected documents by following the steps in the previous section.

  3. You can e-file one or multiple documents:

    • To e-file a single document, open it using the link in the table. Select Other options... > Efile document.

    • To e-file multiple documents, select them from the table. Go to Other Options... > Efile documents.