BOI filing concierge service

Governing rule, scope, and current status (authoritative guidance): FinCEN is the federal administrator of BOI reporting under the Corporate Transparency Act. As of the March 26, 2025 interim final rule, FinCEN removed the BOI reporting requirement for entities created in the United States (domestic reporting companies) and U.S. persons; existing foreign entities registered to do business in the U.S. remain subject to reporting.

FinCEN’s pages and Small Entity Compliance Guide describe these changes and the applicable deadlines for foreign reporting companies. Practical implication: BOI is a federal requirement; state filings (LLC annual reports, etc.) generally do not satisfy federal BOI reporting obligations.

Concierge services must therefore focus on FinCEN rules first and verify any additional state-level disclosure requirements separately per state. 2) Who must file, what must be reported, and deadlines: ‘Reporting companies’ (as currently defined after the March 26, 2025 interim final rule) are generally foreign entities registered to do business in the U.S. that are not exempt.

FinCEN provides flowcharts and checklists for the 23 statutory exemption categories (e.g., many nonprofits, publicly traded companies that meet criteria, certain large operating companies). Initial filing timelines (authoritative): reporting companies registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025.

Companies registered on or after March 26, 2025 must file within 30 calendar days after receiving notice that registration is effective. Earlier transitional deadlines (for companies formed in 2024, e.g., 90 days) are captured in FinCEN guidance and the FAQs and Small Entity Compliance Guide.

What to report: reporting company identifying information (legal name, trade name, EIN/TIN if any, business address — must be U.S. street address, not P.O. box), beneficial owner(s) info, and for some companies company applicant(s) if created/registered on/after Jan 1,

FinCEN’s Small Entity Guide and FAQs describe specific fields and address rules.

Updates/corrections and enforcement

Updated reports: any change to required information must be reported no later than 30 days after the change. Corrected reports: inaccuracies must be corrected within 30 days after the company knows or has reason to know of the inaccuracy. FinCEN’s FAQ and guide describe these timeframes. Penalties: willful violations can carry civil penalties adjusted for inflation (example amount cited: $591 per day) and criminal penalties up to $10,000 and up to two years imprisonment. FinCEN’s FAQs and the Small Entity Compliance Guide discuss enforcement and possible relief if corrected within 90 days of a deadline.

Filing mechanics and third-party filers

Filings are submitted via the FinCEN BOI E-Filing System (boiefiling.fincen.gov). Filers may create a FinCEN ID (optional) and third-party service providers (including non-attorneys) can prepare and submit reports on a company’s behalf; state rules on unauthorized practice of law may still apply. FinCEN supports API submission for third-party providers. There is no fee for submitting a BOI report to FinCEN.

Market examples and service design (concierge offering elements)

Typical concierge features seen in market examples: white-glove intake and documentation collection, exemption assessment, preparation and professional review, filing/submission via BOI e-filing portal (or API), confirmation and record delivery, ongoing monitoring and update alerts, unlimited client access to a dedicated compliance specialist, and remediation of rejected filings (some providers offer an accuracy guarantee). Pricing ranges from free (DIY via FinCEN) to low-cost SaaS ($129/year for self-service + professional-review tiers) to per-report professional fees (commonly $400–$600 for a professional review/filing) and full-service concierge subscriptions or flat-fee engagements (example marketplace pricing observed at ~$999/yr for comprehensive concierge services; custom quotes for complex or multi-entity engagements are common).

Practical checklist (what a BOI concierge must collect from a client)

Company documents: formation/registration document, state filing/foreign qualification evidence and effective date, EIN/TIN or foreign TIN, any previous BOI filings or exemption certificates. Beneficial owner documentation: full legal name, date of birth, residential address (U.S. street address), unique identifying number (SSN/ITIN/EIN/foreign TIN) and a copy of an acceptable ID (passport or state ID) where required by the service provider (FinCEN requires a unique identifying number and issuing jurisdiction when available). Company applicant information (if applicable): name, address, identifying number, and ID copy. Authorization: written authorization to file on client’s behalf; client attestations/certifications.

Operational and compliance considerations for a concierge service

Data security: PII/BI must be handled securely — encryption at rest/in transit, strict access controls, secure client portals, retention policies, and (ideally) SOC2-level controls or equivalent. FinCEN describes that BOI is stored in a secure non-public database and highlights access safeguards. Recordkeeping & client file: retain copies of submitted reports, client authorizations, and evidence supporting exemption claims (e.g., financial statements for large operating company exemption), and logs of communications. Authorization and malpractice/unauthorized practice of law risk: obtain written filing authorization; if providing legal analysis about exemptions, work with counsel or clarify the service does not constitute legal advice (or offer attorney-reviewed packages). API integration and scale: FinCEN supports third-party API submissions; concierge platforms can integrate for batch filing, client dashboards, and monitoring.

State-specific guidance (how to handle state interplay in the blog)

Emphasize that BOI is a federal reporting obligation — state LLC/corporation filings do not replace BOI filings. Concierge content should advise clients to: (a) confirm the company’s formation/registration effective date with the secretary of state to determine BOI deadlines; (b) check for any state-level ownership disclosure requirements (some states may have separate transparency rules or reporting for particular industries); and (c) maintain good standing and address changes (e.g., foreign qualification effective date affects BOI timelines). Because the user did not supply geotag states, recommend a short paragraph in the blog instructing readers to check their secretary of state site and offering concierge assistance for state-specific checks.