Updated BOI Reports

Understanding Beneficial Ownership Information Reports

Beneficial Ownership Information Reporting: Updates and Corrections

When to update a beneficial ownership information report: After a reporting company files an initial beneficial ownership report, the reporting company must file an amended report within 30 calendar days after the date on which such change occurs to reflect any change in information previously reported to FinCEN, including any change with respect to who is a beneficial owner or information reporting for any particularly beneficial owner.
When to correct a beneficial ownership information report: If a reporting company files an initial beneficial ownership report or any subsequent amendment and determines that either report was inaccurate when filed and remains inaccurate the reporting company must file a corrected report within 30 calendar days after the date on which the reporting company becomes aware of or has reason to know if the inaccuracy.

Understanding the Need for Updated Beneficial Ownership Information Reports

When to File an Updated Report: Reporting companies are required to file updated beneficial ownership information reports within 30 days of any change in their beneficial ownership information. Updated reports are required if there are any changes to reported information about the reporting company or its beneficial owners. Remember, required information on a beneficial ownership information report includes, in part, a reporting company’s name and address and a beneficial owner’s name, address, and identifying number from an acceptable identification form. Any change to any of these items can trigger the legal obligation to file an updated beneficial ownership information report. Reporting companies are not required to provide updated information about company applicants.

Action Steps for Reporting Companies:

Identify Changes: Regularly review your company’s beneficial ownership structure to identify any changes that may trigger the need for an updated beneficial ownership information report.
Gather Information: Require all beneficial owners to always update their beneficial ownership information, ensuring accuracy in names, addresses, and unique identifying numbers.
File Promptly: Prepare and submit the updated beneficial ownership information report within the 30-day window to avoid noncompliance.

Addressing the Need for Corrected Beneficial Ownership Information Reports

When to File a Corrected Report: In the event that a reporting company discovers an error or omission in a previously filed beneficial ownership information report, a corrected report must be filed within 30 days. This ensures that the information on record with FinCEN is accurate.

Action Steps for Reporting Companies:

Review and Identify Errors: Conduct thorough reviews of your beneficial ownership information reports to verify the accuracy of the information provided.
Prepare the Correction: Assemble all necessary information to correct any error or omission, ensuring that the new report is complete and precise.
File Without Delay: Submit the corrected beneficial ownership information report promptly to avoid any penalties that FinCEN could impose.

Our Role in Your Reporting Obligations

At Kim & Rosado LLP, we understand that maintaining compliance with evolving regulations can be challenging. Our partners stand ready to assist you in fulfilling your beneficial ownership information reporting obligations with precision and authority.

Should you require assistance in preparing updated or corrected beneficial ownership information reports, or if you have any questions regarding these processes, we invite you to reach out to us. Our direct involvement and hands-on approach ensure that you receive the expert advocacy and support needed to navigate these intricate regulatory requirements.