FinCEN’s BOI reporting under the Corporate Transparency Act is live as of Jan 1, 2024 — new entities formed in 2024 have 90 days to file, existing companies have until Jan 1, 2025, and the March 2024 Alabama ruling limiting enforcement applies only to the named plaintiffs. I’m tightening our governance calendar and signatory records to stay compliant; for specific situations please consult a qualified attorney — how are you tracking filings and officer changes across entities?
We added BOI deadlines to DocuSign templates; @OP’s 90-day reminder helped — also bookmark Beneficial Ownership Information Reporting | FinCEN.gov; check counsel for edge cases.
I set a BOI ‘change trigger’ in our closing checklist (board consents, signatory swaps) and started collecting FinCEN IDs from owners so the filing’s faster. Heads-up: updates are due within 30 days of changes, and that 90-day window for new entities shrinks to 30 days in 2025 — check counsel if your structure’s quirky. Piggybacking on @ethanField_14, a one-pager defining “company applicant” plus Beneficial Ownership Information Reporting | FinCEN.gov has kept debates short, and my calendar now looks like a traffic light.
One tweak that’s saved me time: for any entity formed after Jan 1, 2024, I capture the ‘company applicant’ details at the moment we submit the state filing, then lock them in our entity record so the three-month BOI clock isn’t a scramble. If a filing service is involved, I confirm upfront whether they’ll share their info; if it’s murky, I loop in counsel for the specifics, @OP.
Following @ethanField_14, I started attaching a one-page “BOI snapshot” to each new entity record right after formation — applicant details, owner IDs, and the source docs — so updates don’t turn into a scavenger hunt. I also drop a dated PDF of whatever we relied on (DL, passport, address proof) in the same folder to show what we filed. If the ownership stack gets layered or crosses borders, I loop in counsel first.