NOTE: As BOI regulations continue to evolve, please see our BOI Reporting Resource Center for the most up-to-date reporting deadline information.
The beneficial ownership information reporting obligations under the federal Corporate Transparency Act require a reporting company to provide certain information about their organization and each beneficial owner and applicant.
If you’re the reporting company, you must provide full legal name; trade name or DBAs, if applicable; U.S. business address; state, tribal or foreign jurisdiction information; and your IRS TIN or EIN. On the beneficial owner and applicant side, the information is more detailed. They must include full legal name; date of birth, primary residence or business address, identifying number and issuing jurisdiction, and an image of a non-expired document, such as a U.S. passport, driver’s license or FinCEN identifier.
But how do you actually go about submitting your information? There are two primary methods through the FinCEN website: PDF document and online portal. Each has unique features, advantages and potential challenges. Below is a comparison to help you determine which method best suits your needs.
Below is the process to submit via PDF.
Download and Save: You can download the form from the FinCEN portal and save it on your desktop with a new name. This allows you to work on the form at your own pace and save your progress. Note, if there are special characters in the file name, it will not allow you to submit the final form.
Validation: The form includes a validation feature when you’re ready to submit. Clicking “validate” locks in your information and alerts you if there are any missing data points. Note, it will not check for spelling errors or mistyped information.
Submission: Once ready to file, clicking the “Submission” button will direct you to the FinCEN website to sign off as the submitter and upload the file. A "Submission Process” screen will appear, and a confirmation page will populate once the process is complete.
Navigation: Note that navigating from field to field in the PDF form can be a bit clunky compared to the online form.
Below is the process to submit when inputting your information via the FinCEN portal.
No Saving: Unlike the PDF method, via the online method you cannot save the form once you’ve begun. If you leave the site before completing your submission, all the information you’ve entered will be lost. Unfortunately, there is no way to save your progress or a draft of the file.
Automatic Validation: The online form automatically validates the fields as you enter them.
Submission: The submission process is almost identical to the PDF method. You will sign off as the “authorized filer” and the "Submission Process” screen will appear, followed by a confirmation page once the process is complete.
Whether you decided to submit online or use the PDF option, your submission experience will be the same in a couple of ways:
The choice between PDF and online filing depends on your specific needs and preferences. If you prefer a more free-flowing form and automatic validation of your information, online filing might be for you. However, if you want the ability to save your progress and work at your own pace, then PDF filing could be the better option.
For more information related to filing Beneficial Ownership Information, please visit https://www.fincen.gov.
Contact Jason Jones or a member of your service team to discuss this topic further.
Cohen & Co is not rendering legal, accounting or other professional advice. Information contained in this post is considered accurate as of the date of publishing. Any action taken based on information in this blog should be taken only after a detailed review of the specific facts, circumstances and current law.