BOI compliance for founders with no U.S. phone number

I performed targeted searches of authoritative sources (FinCEN pages and Federal Register), high-quality guidance (compliance blogs and industry commentary), and practical community reports to gather up-to-date, authoritative, and practical information about BOI (Beneficial Ownership Information) compliance for founders who do not have a U.S. phone number. I focused on: who must report under the current FinCEN rule (including the March 2025 interim final rule), what information is required about beneficial owners and filers, acceptable identification and address rules (including use of registered agent addresses), options when individuals lack U.S. tax IDs (EIN/SSN/ITIN), the role of authorized filers and FinCEN Identifiers, and practical steps a founder without a U.S. phone number should take. Summary of key findings and practical implications for founders with no U.S. phone number 1) Regulatory scope has changed (March 2025 interim final rule): - FinCEN issued an interim final rule (March 21/26, 2025) that removed the BOI reporting obligation for entities formed in the United States (previously called "domestic reporting companies"). The revised definition of "reporting company" now generally covers only entities formed under foreign law that have registered to do business in a U.S. State or Tribal jurisdiction (i.e., foreign reporting companies). The rule sets new filing deadlines for foreign reporting companies. (See FinCEN main BOI page and Federal Register notice.) Practical implication: Many U.S.-formed LLCs and other domestic companies are no longer required to submit BOI reports under the interim final rule. Founders of U.S.-formed businesses should confirm whether their entity is a domestic company (likely exempt under the current IFR) or a foreign reporting company (still required to file). 2) Who can file and what contact info is required from the filer (important for founders without a U.S. phone): - FinCEN states that "Anyone a reporting company authorizes to act on its behalf—such as an employee, owner, or third-party service provider—may file a BOI report on its behalf." When submitting the BOI report, individual filers should be prepared to provide basic contact information about themselves, including their name and email address. (FinCEN BOI FAQs.) Practical implication: A founder without a U.S. phone number can (a) file directly (the system expects name and email rather than requiring a U.S. phone), (b) use an authorized third-party filer (attorney, registered agent, formation provider) who will provide their contact info and certify the filing, or (c) get a FinCEN Identifier and use that where permitted to minimize repeated disclosure of personal details. 3) Information required about beneficial owners and acceptable IDs/address formats: - For each beneficial owner, reporting companies must provide: name, date of birth, residential address, and an identifying number from an acceptable ID (U.S. driver’s license or state ID, U.S. passport, or foreign passport when other U.S. IDs are not available). FinCEN’s FAQs and guides also note that a company may report its U.S. principal place of business address, and that a registered agent’s address can be reported if the registered agent has consented and the company does not conduct business at other U.S. locations. Practical implication: Founders living outside the U.S. can generally supply a foreign residential address and a foreign passport as acceptable ID (if they lack U.S. ID). The reported company U.S. address can be a registered agent’s address if that agent has consented and the business does not operate from another U.S. location. 4) Tax identification numbers (TINs) and filing timing constraints: - Reporting companies must report a TIN if they have one (EIN, SSN, or ITIN). FinCEN notes that if a reporting company cannot obtain an EIN in time (for example, because a foreign responsible party has no SSN/ITIN and cannot use the online EIN process), it should make reasonable efforts to obtain the EIN and file the BOI report as soon as the EIN is assigned, retaining documentation of efforts. FinCEN describes options (mail/fax SS-4) and typical processing times. Practical implication: Founders without SSN/ITIN can obtain an EIN via the IRS (fax or mail process) for entities; it can take several weeks. If a BOI filing deadline would pass before an EIN is received, document the efforts and file promptly once the EIN is issued. 5) FinCEN Identifier and privacy/efficiency options: - FinCEN supports a FinCEN Identifier: individuals and company applicants can apply for an identifier that can be used on BOI reports in lieu of full identifying information. FinCEN highlights potential privacy and administrative benefits of using identifiers. Practical implication: Foreign founders who expect to be listed as beneficial owners of multiple reporting companies (or who prefer to limit repeated disclosure of personal data) can apply for a FinCEN Identifier and provide that on BOI reports. 6) Use of authorized filers / formation service providers: - FinCEN explicitly allows reporting companies to authorize employees, owners, or third-party service providers to file BOI reports on their behalf. The filer must provide contact information (name, email) and certify the report. Practical implication: If founders lack a U.S. phone or prefer not to interact directly with the FinCEN portal, they can authorize a U.S. registered agent, attorney, or compliance provider to file on their behalf. That authorized filer’s contact details (name and email) will be used in the filing. 7) State-level interactions and addresses: - The BOI reporting system and the current FinCEN rule are federal in nature. State Secretary of State offices handle entity formation/registration and may have their own address/phone requirements for state filings, but BOI filings are submitted to FinCEN. FinCEN’s guidance notes how to report the company’s U.S. principal place of business or, if the company is foreign, the address from which it conducts business in the U.S. Registered agent addresses can be reported in particular circumstances (with consent). Practical implication: Founders should check state SOS forms for any phone/address requirements for formation or registration, but BOI contact fields primarily require name and email for filers (not a U.S. phone). Using a registered agent is a common and acceptable approach for a U.S. mailing address where appropriate. 8) Deadlines (post-March 2025 interim final rule): - FinCEN’s main BOI page and the Federal Register IFR state that foreign reporting companies registered before March 26, 2025, had initial filing deadlines (e.g., April 25, 2025), and companies registered on or after March 26, 2025, generally have 30 calendar days to file after registration becomes effective. The interim final rule extended deadlines and addressed revisions; FinCEN is accepting comments and intends to issue a final rule later. Practical implication: Founders of foreign entities registered to do business in the U.S. should confirm the applicable deadlines for initial reports and updates. Founders of domestic (U.S.-formed) companies should verify exemption status under the IFR but keep monitoring FinCEN for any future rule changes or final rule. 9) Penalties and enforcement (high-level guidance): - FinCEN previously implemented enforcement provisions under the Corporate Transparency Act; however, because of the March 2025 IFR exempting domestic companies, enforcement focus will vary depending on entity type and future rulemaking. Founders should consult FinCEN guidance and legal counsel for up-to-date enforcement risk and penalty structures relevant to foreign reporting companies and any residual reporting obligations. Practical implication: Don’t assume no consequences—if your entity is required to file, follow FinCEN guidance and retain documentation of efforts to comply (especially when delays occur obtaining TINs). Sources (verbatim excerpts associated with each citation) 1) FinCEN BOI FAQs — https://www.fincen.gov/boi-faqs - Excerpts: "Anyone a reporting company authorizes to act on its behalf—such as an employee, owner, or third-party service provider—may file a BOI report on its behalf. When submitting the BOI report, individual filers should be prepared to provide basic contact information about themselves, including their name and email address." [B.8] "For each individual who is a beneficial owner, a reporting company will have to provide: 1. The individual’s name; 2. Date of birth; 3. Residential address; and 4. ..." [F.3] "What are acceptable forms of identification that will meet the reporting requirements?... 1. A non-expired U.S. driver’s license... 3. A non-expired passport issued by the U.S. government; or 4. A non-expired passport issued by a foreign government (permitted only when an individual does not have one of the other three forms of identification listed above)." [F.5] "In some jurisdictions, this person is referred to as the reporting company’s registered agent, or the address is referred to as the registered office. Such a reporting company should report this address to FinCEN as its address. FinCEN will understand the use of such an address to mean that: (i) the registered agent or other person at the address designated to accept service of legal process has consented to the use of its address in this capacity, and (ii) the reporting company does not generally conduct business functions at any other location in the United States." [Updated October 3, 2024] "A reporting company must provide one of the following types of taxpayer identification numbers (TINs) on its BOI report if it has been issued a TIN: an Employer Identification Number (EIN); a Social Security Number (SSN); or an Individual Taxpayer Identification Number (ITIN)." [F.13] 2) FinCEN BOI main page (Alert and rule change) — https://www.fincen.gov/boi - Excerpt: "Alert: FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies... FinCEN published this interim final rule on March 26, 2025. In the interim final rule, FinCEN revises the regulatory definition of 'reporting company' to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction (formerly known as 'foreign reporting companies'). FinCEN also exempts entities previously known as 'domestic reporting companies' from BOI reporting requirements." [FinCEN BOI page] "The following deadlines apply for foreign entities that are reporting companies: Reporting companies registered to do business in the United States before March 26, 2025, must file BOI reports by April 25, 2025. Reporting companies registered to do business in the United States on or after March 26, 2025, have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective." [FinCEN BOI page] 3) Federal Register — Interim Final Rule — https://www.federalregister.gov/documents/2025/03/26/2025-05199/beneficial-ownership-information-reporting-requirement-revision-and-deadline-extension - Excerpt: "FinCEN has revised the rule text such that foreign pooled investment vehicles must report the BOI of an individual who exercises substantial control over the entity if that individual is not a U.S. person... This interim final rule otherwise retains the requirement for foreign reporting companies, and their beneficial owners (excluding U.S. persons), to report their BOI to FinCEN, while extending the deadline for those companies to file initial BOI reports, or update or correct previously filed BOI reports, to 30 days after the date of this publication or 30 days after their registration to do business in the United States, whichever comes later." [Federal Register, March 26, 2025] 4) FinCEN News Release (IFR summary) — https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us - Excerpt: "FinCEN is issuing an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN..." [FinCEN news release, March 21, 2025] 5) Practical guidance / industry commentary (Kitces) — https://www.kitces.com/blog/financial-crimes-enforcement-network-fincen-beneficial-ownership-information-boi-reporting-corporate-transparency-act/ - Excerpt: "The Beneficial Ownership Information (BOI) report itself... consists at a high level of 3 sections... The company's U.S. address (i.e., the location of its principal place of business). For the second and third sections, companies must report the individual's name; their date of birth; their home address; their state ID (e.g. driver's license) number, U.S. passport number, or, if neither of those are available, a foreign passport number; and an uploaded picture of the ID listed above. Some individuals and companies may find it useful to request a FinCEN Identifier number, which is a unique ID number that can be entered on the BOI reporting form in lieu of all the information above." [Kitces] Overall conclusion and recommended next steps for content creation targeted to US business owners/LLC founders (especially founders without a U.S. phone): 1. Emphasize the March 2025 interim final rule: confirm whether the user's company is domestic (likely exempt under IFR) or a foreign reporting company (still required to file). Cite FinCEN pages and the Federal Register. 2. Explain what BOI filings require: details on beneficial owners, acceptable IDs, addresses, and TINs—highlight that filers need name and email (not necessarily a U.S. phone). Use FinCEN FAQs and BOI guidance to support this. 3. Provide practical, step-by-step guidance for founders with no U.S. phone number: use a registered agent for a U.S. address (with consent), supply a foreign residential address and foreign passport as ID if no U.S. ID, obtain an EIN (use IRS mail/fax if no SSN/ITIN), consider applying for a FinCEN Identifier, or authorize a third-party filer (attorney or formation provider) to file on your behalf. 4. Add state-specific notes: explain that state SOS filings may have their own address/phone requirements (check the state), but BOI is filed with FinCEN; include guidance on using registered agents and differences between state and federal filings. 5. Recommend documentation and compliance hygiene: keep copies of efforts to obtain TINs and other required documents, retain proof of registered agent consent, and monitor FinCEN for final rulemaking and future changes. I am ready to generate the full comprehensive blog post and newsletter content (including suggested structure, sample language for founders without a U.S. phone number, SEO meta, and state-level notes). The research above included the authoritative FinCEN sources and practical guidance needed to craft the content.