So you’ve filed your initial Beneficial Ownership Information Report (BOIR). Congratulations are in order! But your obligations do not end there. Under the CTA, you need to monitor your company and beneficial owners because if any previously reported information changes, you are required to file an updated BOIR. Updated BOIRs are due within 30 calendar days after the change occurs.
The following are some examples of the changes that would require an updated BOIR:
- Any change to the information reported for the reporting company, such as registering a new business name.
- A change in beneficial owners, such as a new CEO, or a sale, gift or other transfer that changes who meets the ownership interest threshold of 25 percent.
- Any change to a beneficial owner’s name, address, or unique identifying number previously provided to FinCEN. If a beneficial owner obtained a new driver’s license or other identifying document that includes a changed name, address, or identifying number, the reporting company also would have to file an updated BOIR with FinCEN, including an image of the new identifying document.
- When a beneficial owner that was a minor child reaches the age of majority, you must file an updated BOIR, identifying the individual as a beneficial owner and, if warranted, replacing their parent or legal guardian’s information with their own.
- When a beneficial owner dies, resulting in changes to the reporting company’s beneficial owners, report those changes within 30 days of when the deceased beneficial owner’s estate is settled. The updated report should, to the extent appropriate, identify any new beneficial owners.
- If your company filed an initial BOIR and later qualifies for an exemption from the reporting requirements, your company should file an updated BOIR to indicate that it is newly exempt from the reporting requirements.
The good news is that a reporting company is not required to file an updated report for any changes to previously reported information about a company applicant. In addition, there is no requirement to report a company’s termination or dissolution. And finally, a change to the type of ownership interest a beneficial owner has in a reporting company—for example, a conversion of preferred shares to common stock—does not require the reporting company to file an updated BOIR because FinCEN does not require companies to report the type of interest.
File your Beneficial Ownership Information Report in just minutes with BOIFox.