Beneficial Ownership Information (BOI) Reporting for Your Business
What is a BOI Report?
The Beneficial Ownership Information (BOI) report is a new type of report required by the U.S. federal government that discloses the owners of a business. Most businesses are required to file the BOI report with the Financial Crimes Enforcement Network (FinCEN) between January 1, 2024 and January 1, 2025. This report was created to help increase transparency of businesses and help fight illicit activity through the use of business structures. There are civil penalties if the BOI report is filed late and criminal penalties for willfully failing to file. BOI reports must be updated within 30 days if there are any changes, and businesses will be required to file an updated BOI if any information changes such as address, or the addition or reduction of owners. Read below to learn more about this report.*
*While our Business Services team can provide some guidance on this matter, specific questions on beneficial ownership and your potential requirement to file the BOI report should be referred to your legal counsel as our team does not file beneficial ownership information on a customer’s behalf with the Financial Crimes Enforcement Network.
Do I need to file a BOI report for my business?
The general rule is, if you filed documents with the secretary of state — or any similar office under the law of a state or Indian tribe — when establishing your business, you may need to file the BOI report. There are a limited number of entities exempt from filing. Here are some examples where you may not need to file a report:
- Sole proprietors doing business under their own name (no corporation or LLC)
- General partnerships (no filing done with secretary of state)
- Larger businesses and non-profit organizations*
- Highly regulated industries
- Examples include: publicly traded businesses, governmental authorities created by federal, state, or tribal governments, banks and credit unions, money transmitters, securities brokers and dealers, investment companies and advisors, venture capital fund advisers, insurance companies or producers, commodities brokers and dealers, public accounting firms, public utility companies, pooled investment vehicles, and inactive businesses
*For large businesses, you must meet all of the following criteria: over $5 million in gross revenue reported on the previous year's tax return and without any foreign-source revenue, business employs over 20 full-time employees in the United States, and have a physical office location in the United States. For non-profit organizations, you must meet one or more of the following criteria: an organization that received IRS approval for tax-exempt status under Internal Revenue Code section 501(c), a political organization that is tax-exempt under section 527(a), or an organization that is a trust under section 4947(a).
Who needs to be included on my BOI report?
See the table below for a timeline on filing your initial report and an updated report if changes are to occur.
| Established Date | Initial Report | Updated Report |
| Business entities already formed or incorporated before 1/1/2024 | Between 1/1/2024 and 1/1/2025 | Required within 30 days after any changes occur |
| Business entities formed or incorporated on or after 1/1/2024 OR 1/1/2025 | Within 90 days of receiving notice that their business entity was created or registered at the state level | Required within 30 days after any changes occur |
Who needs to be included on my BOI report?
On the BOI report, you must identify the company’s beneficial owners. A beneficial owner is any individual who, directly or indirectly, exercises substantial control over the reporting company or owns/controls at least 25% of the ownership interests of the reporting company. The following information on each company and each beneficial owner must be included:
| Company Information | Beneficial Owner Information |
| Full legal business name | Full legal name |
| Any DBA or trade name used by the business | Date of birth |
| Street Address of the company's primary place of business | Street address of current residence |
| The jurisdiction where the business was formed or registered | Identification number from a non-expired, government issued photo ID, along with the name of the issuing state (such as driver's license or passport) |
| The company's EIN (taxpayer ID number) | An image of the photo ID from which the identifying information was obtained |
What if I fail to file my BOI report on time?
Failing to file the required information through FinCEN by the required date of January 1, 2025 could have significant consequences. There are two levels of penalties that you could face, civil and criminal.
Failing to file can result in civil penalties starting at $591 per day after the January 1, 2025 due date.
For someone who willfully fails to file is subject to a maximum civil penalty of $10,000 and could face criminal penalties of up to two years in prison.
How do I prepare now for BOI filing?
While Farm Credit’s Business Services team can provide some guidance on this matter, specific questions on beneficial ownership and your potential requirement to file the BOI report should be referred to your legal counsel as our team cannot file beneficial ownership information on a customer’s behalf with FinCEN.
Here are some recommended “to-do’s” in preparation for filing:
- Review your list of business owners and key employees.
- Collect the Beneficial Owner personal information and make sure is up to date.
- Review your by-laws or operating agreements. You may need to add language that requires company’s beneficial owners to provide the business with required information.
Consult with your attorney for additional support in your by-laws and filing requirements. - Do your research at Beneficial Ownership Information Reporting | FinCEN.gov
- A reporting company can file online through the FinCEN BOI website at BOI E-FILING (fincen.gov)
If you have questions or need guidance on filing, a member of our Business Services team may be able to help. With increasing complexities in accounting, a member of our team may be the solution to your accounting and consulting needs. Visit our Business Services page to learn more or contact us today at 888.339.3334!