FINCEN ADDS TO ITS BOI REPORTING FAQS:

The Financial Crimes Enforcement Network (FinCEN) added or updated 18 questions regarding the reporting of beneficial ownership information (BOI) on its frequently asked questions (FAQs) webpage. The questions that have been added or updated since January 1 include:

• Under the Corporate Transparency Act (CTA), who can access beneficial ownership information?
• The company applicants of a reporting company include the individual “primarily responsible for directing the filing of the creation or registration document.” What makes an individual “primarily responsible” for directing such a filing?
• If a beneficial owner or company applicant's acceptable identification document does not include a photograph for religious reasons, will FinCEN accept the identification document without the photograph?
• What residential address should be reported if a reporting company is required to report an individual's residential address, but that individual does not have a permanent residence?
• What should a reporting company report if its ownership is in dispute?
• Who does a reporting company report as a beneficial owner if a corporate entity owns or controls 25% or more of the ownership interests of the reporting company?
• Can a company created or registered in a U.S. territory be considered a reporting company?

New companies created or registered in 2024 have 90 days from receiving notice of the entity's creation or registration to file a BOI report with FinCEN. Companies created or registered before 2024 must file BOI reports by Jan. 1, 2025.