The federal government, through the Financial Crimes Enforcement Network of the United States Treasury Department (“FinCEN”), has implemented a sweeping program—the Beneficial Ownership Information (“BOI”) program. The stated goal of the program is to discover companies that are owned or controlled by “bad actors.”
This program is mandatory and will affect most if not all of the corporations and limited liability companies in which people in the real estate and general business fields are involved, as well as many partnerships, primarily limited partnerships and partnerships that own real estate.
BOI Program Requirements
The BOI program requires each such company, unless exempted under 23 stated FinCEN exemptions, to file an online report to FinCEN, providing certain specified items of information for:
- the company,
- the individual filling out the online form, and
- each individual who owns at least 25% of the company or who exercises substantial control over the company.
Reporting Deadlines
The reports must be filed online with FinCEN by:
- December 31, 2024 for all companies created before January 1, 2024.
- Within 90 days after filing for those companies formed in 2024.
- 30 days after filing for companies formed in 2025 and beyond.
Penalties
The penalty for failure to file a report by the deadline is $500.00 per day.
Request Your Step-by-Step BOI Program Guide
Steeg Law has created a Step-by-Step BOI Program Guide that provides a detailed outline of the steps that need to be taken to determine whether you must file a form and show you how to file that form.
If you would like to obtain a copy of our Step-by-Step BOI Program Guide, please email Robert Steeg at rsteeg@steeglaw.com.