BOI compliance support for multi-channel creators

Summary and recommended guidance for BOI compliance support for multi-channel creators (US business owners / LLC founders) Key findings - Major change: On March 26, 2025 FinCEN issued an interim final rule narrowing the definition of “reporting company” under the Corporate Transparency Act (CTA).

Under that rule, entities formed in the United States (i.e., domestic companies) and their beneficial owners are exempt from BOI reporting to FinCEN. Reporting companies are now entities formed under the law of a foreign country that have registered to do business in any U.S. state or tribal jurisdiction by filing a document with a secretary of state (i.e., foreign entities registered in the U.S.). (FinCEN BOI homepage; Small Entity Compliance Guide; Interim Final Rule Q&A) - Deadlines for foreign entities: foreign entities already registered to do business in the U.S. before March 26, 2025 had to file BOI reports by April 25, 2025; foreign entities registering on/after March 26, 2025 generally have 30 calendar days after their registration is effective to file an initial BOI report. (FinCEN BOI homepage; Small Entity Compliance Guide) - FinCEN now exempts reporting of BOI for U.S. persons; reporting companies do not need to report BOI of U.S. persons and U.S. persons are not required to provide BOI with respect to reporting companies. (FinCEN BOI homepage; IFR Q&A) - Required BOI fields (when required): reporting company identity (name, trade name, principal place of business, jurisdiction, and TIN) and for each beneficial owner: full legal name, date of birth, residential address, and unique identifying number from an acceptable ID (passport/driver’s license) — consistent with FinCEN’s Small Entity Compliance Guide and FAQs. (FinCEN FAQs; Small Entity Compliance Guide) - Penalties and enforcement: willful violations may carry civil penalties (statutory up to $500/day, adjusted for inflation — FAQ cited $591 as an amount in guidance), criminal penalties up to 2 years imprisonment and fines up to $10,000, and companies/individuals may be held liable.

FinCEN provides a 90‑day safe harbor for correcting errors if voluntarily corrected. (FinCEN FAQs; Small Entity Compliance Guide) - State-level rules: some states are adopting or considering state-level beneficial ownership/LLC transparency laws (New York enacted an LLC Transparency Act requiring certain LLC filings to the NY Dept. of State effective Jan 1, 2026; California had proposed legislation and other states have guidance pages).

State regimes can differ from federal rules in scope, timing, public access, and enforcement — creators must check their specific Secretary of State / Department of State rules. (NY DOS guidance; NYLTA summaries; CA SOS notices; Texas SOS guidance) Practical checklist for multi-channel creators (tailored steps) 1.

Confirm entity formation jurisdiction - Are you a domestic U.S. entity (formed in any U.S. state) or a foreign-formed entity (created under foreign law and registered in a U.S. state)? Domestic U.S. entities are currently exempt from FinCEN BOI reporting under the March 26, 2025 interim final rule; foreign entities registered to do business in the U.S. may still have reporting obligations.

Summary and recommended guidance for BOI compliance support for multi-channel creators (US business owners / LLC founders) Key findings - Major change: On March 26, 2025 FinCEN issued an interim final rule narrowing the definition of “reporting company” under the Corporate Transparency Act (CTA).

Under that rule, entities formed in the United States (i.e., domestic companies) and their beneficial owners are exempt from BOI reporting to FinCEN. Reporting companies are now entities formed under the law of a foreign country that have registered to do business in any U.S. state or tribal jurisdiction by filing a document with a secretary of state (i.e., foreign entities registered in the U.S.). (FinCEN BOI homepage; Small Entity Compliance Guide; Interim Final Rule Q&A) - Deadlines for foreign entities: foreign entities already registered to do business in the U.S. before March 26, 2025 had to file BOI reports by April 25, 2025; foreign entities registering on/after March 26, 2025 generally have 30 calendar days after their registration is effective to file an initial BOI report. (FinCEN BOI homepage; Small Entity Compliance Guide)

- Penalties and enforcement: willful violations may carry civil penalties (statutory up to $500/day, adjusted for inflation — FAQ cited $591 as an amount in guidance), criminal penalties up to 2 years imprisonment and fines up to $10,000, and companies/individuals may be held liable.

FinCEN provides a 90‑day safe harbor for correcting errors if voluntarily corrected. (FinCEN FAQs; Small Entity Compliance Guide) - State-level rules: some states are adopting or considering state-level beneficial ownership/LLC transparency laws (New York enacted an LLC Transparency Act requiring certain LLC filings to the NY Dept. of State effective Jan 1, 2026; California had proposed legislation and other states have guidance pages).

State regimes can differ from federal rules in scope, timing, public access, and enforcement — creators must check their specific Secretary of State / Department of State rules. (NY DOS guidance; NYLTA summaries; CA SOS notices; Texas SOS guidance) Practical checklist for multi-channel creators (tailored steps) 1.

Confirm entity formation jurisdiction - Are you a domestic U.S. entity (formed in any U.S. state) or a foreign-formed entity (created under foreign law and registered in a U.S. state)? Domestic U.S. entities are currently exempt from FinCEN BOI reporting under the March 26, 2025 interim final rule; foreign entities registered to do business in the U.S. may still have reporting obligations.

• FinCEN now exempts reporting of BOI for U.S. persons; reporting companies do not need to report BOI of U.S. persons and U.S. persons are not required to provide BOI with respect to reporting companies. (FinCEN BOI homepage; IFR Q&A)
• Required BOI fields (when required): reporting company identity (name, trade name, principal place of business, jurisdiction, and TIN) and for each beneficial owner: full legal name, date of birth, residential address, and unique identifying number from an acceptable ID (passport/driver’s license) — consistent with FinCEN’s Small Entity Compliance Guide and FAQs. (FinCEN FAQs; Small Entity Compliance Guide)

Check your state-specific requirements - Look up your Secretary of State / Department of State website (examples

NY DOS, CA SOS, TX SOS). Some states (e.g., New York) enacted state-level disclosure/registry obligations for LLCs; others may have notices or proposed legislation. If you are formed or qualified in those states, follow state filing deadlines and rules.

Identify whether any exemptions apply - Review federal exemptions (as incorporated in state laws that reference CTA exemptions) — e.g., larger operating companies, banks, tax-exempt orgs, etc. For some state regimes you may need to file an attestation of exemption.

Gather required information (if you must file) - Reporting company info

legal name, trade/DBA, principal place of business address, jurisdiction of formation/registration, TIN/EIN. - Beneficial owners: full legal name, date of birth, residential address, and ID info (driver’s license, passport, or other accepted ID number). - Company applicants/filers: who filed the formation/registration document (some state regimes require applicant identity).

File via the correct portal - For BOI reports required by FinCEN (foreign reporting companies), use the BOI E-Filing System ( https

//boiefiling.fincen.gov/ ) and consider obtaining a FinCEN ID ( https://fincenid.fincen.gov ). - For state filings, use the state’s filing system (e.g., NY DOS registry noted in the NY compliance guide; follow state instructions for timing and whether to file an attestation of exemption instead).

Maintain documentation and update promptly - Update or correct BOI reports within required timeframes (FinCEN rules previously required updates within 30 days of a change; check current guidance and state deadlines). FinCEN’s guidance notes voluntary correction within 90 days of a deadline may avoid penalties.

Mitigate privacy and fraud risk - Beware of fraudulent solicitations; there is no fee to file BOI with FinCEN. Use official FinCEN and state portals; do not share ID images beyond required secure submissions. Consider limited sharing internally and use secure storage for identity documents.

When to get professional help - If you are unsure whether your entity is domestic vs foreign for BOI purposes, if you have foreign owners or complex ownership structures (trusts, nominees, intermediaries), or if you're subject to state-level regimes (e.g., NY LLC TA), consult a business attorney or CPA. Compliance service vendors can file for you but confirm legitimacy and fees (FinCEN does not charge any filing fee). Specific guidance for multi-channel creators - Most U.S. creators who form a domestic LLC or corporation in the U.S. (single-member or multi-member) will not need to file BOI with FinCEN under the current interim final rule — but confirm your entity’s status. If you are a U.S. person who formed an LLC in the U.S., you are likely exempt from federal BOI reporting. - If you are a non-U.S. creator (foreign individual/entity) that formed an entity abroad and then registered it in the U.S. (for example, a UK company registering as a foreign LLC in a U.S. state), that foreign reporting company may still have federal BOI obligations and must file with FinCEN within the deadlines noted above. - If you operate multi-channel (YouTube, Patreon, merch, ad networks, payment processors), gather consistent owner information across platforms and from any co‑founders or managers who exercise substantial control, since BOI rules look at ownership >=25% or substantial control. Keep clear records of ownership percentages, operating agreements, and decision-makers. - If your business has a manager/agent or uses third‑party service providers, they may be able to file on your behalf (many state rules and FinCEN guidance permit an authorized filer), but the entity remains responsible for accuracy. Notes on limitations and recommended checks - Federal policy changed in 2025 in a way that materially reduces (or removes) federal BOI filing obligations for U.S.-formed companies — but state-level laws/regimes continue to evolve and may impose obligations (New York is explicitly adopting its own registry; other states have proposals or notices). - For the newsletter/blog, emphasize that the default outcome for most U.S. creators with U.S.-formed LLCs is that no federal BOI report to FinCEN is required under the current interim final rule, but creators should still

(a) verify their entity’s formation status, (b) check state rules (particularly if registered in or formed in a state with active disclosure statutes, e.g., New York), and (c) consult counsel for complex or cross-border ownership.