Urgent BOI filing support

Newsletter draft: "Urgent BOI filing support"Preheader: Immediate action may be required if your business is a foreign entity registered in the U.S.Headline: Urgent Update: Who Must File BOI Reports Now — What US Business Owners Need to DoIntro (2–3 sentences): Important regulatory change from FinCEN (March 2025) narrowed who must file Beneficial Ownership Information (BOI) reports.

If your entity was formed in the United States, you are generally exempt. However, foreign entities that are registered to do business in any U.S.

State or Tribal jurisdiction still may need to file — and deadlines are short. Read the steps below to verify whether your company must file and what to do next.Key takeaways (bullets):- Major change: FinCEN’s interim final rule (March 26, 2025) exempts entities created under U.S. law (domestic companies) and U.S. persons from BOI reporting under the Corporate Transparency Act (CTA). (See FinCEN alert and IFR.)- Who still must file: Reporting companies now principally include entities formed under the law of a foreign country that have registered to do business in a U.S.

State or Tribal jurisdiction by filing a document with a secretary of state or similar office — unless they qualify for another statutory exemption.- Deadlines (for foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had (per FinCEN) until April 25, 2025 to file initial BOI reports; entities that register on or after March 26, 2025 generally have 30 calendar days after their registration becomes effective. (Confirm current deadlines on FinCEN.)- Required filing method: BOI reports are filed electronically through FinCEN’s BOI E-Filing System.

Filers may (optionally) create FinCEN IDs to streamline submissions.- Data required: reporting-company identifying information, beneficial owners’ identifying information (name, date of birth, address, identification document and number or FinCEN ID), and company applicant info where applicable (review FinCEN guidance for the exact required fields and exceptions).- Exemptions and special rules: Multiple exemption categories remain in the CTA and implementing regulations (large operating companies, certain regulated entities, inactive entities, wholly owned subsidiaries, etc.).

FinCEN’s IFR also narrowed BOI reporting for foreign pooled investment vehicles in certain circumstances.- Security & fraud warning: FinCEN has warned of fraudulent solicitations seeking BOI and provides guidance on submitting data only through official FinCEN portals.State-specific guidance (for U.S. businesses / LLC founders):- Most U.S.-created LLCs and corporations: Generally exempt from BOI reporting to FinCEN under the March 2025 interim final rule.

However, U.S. entities should confirm their status (domestic vs foreign) based on where they were formed.- Foreign entities registered in a state: If a foreign company files a document with any state’s secretary of state (or similar office) to register to do business, that state filing is the trigger that may make the entity a FinCEN “reporting company.” Check the filing/registration records with the specific Secretary of State office(s) where you operate — the FinCEN IFR explicitly treats registration with a secretary of state (and territories) as the trigger.- State-by-state action items (general): - If you formed your company in a U.S.

State or territory: you are likely exempt — no FinCEN BOI filing required; retain documentation of formation and counsel review. - If your company was formed outside the U.S. and you registered to do business in any U.S.

State or territory: treat this as potentially reportable — verify registration date(s) and file within FinCEN deadlines. - Use each state’s business search/filing portal to check registration effective dates (these dates determine filing timelines).Practical urgent-filing checklist (what to collect now):

Newsletter draft: "Urgent BOI filing support"Preheader: Immediate action may be required if your business is a foreign entity registered in the U.S.Headline: Urgent Update: Who Must File BOI Reports Now — What US Business Owners Need to DoIntro (2–3 sentences): Important regulatory change from FinCEN (March 2025) narrowed who must file Beneficial Ownership Information (BOI) reports.

If your entity was formed in the United States, you are generally exempt. However, foreign entities that are registered to do business in any U.S.

State or Tribal jurisdiction still may need to file — and deadlines are short. Read the steps below to verify whether your company must file and what to do next.Key takeaways (bullets):- Major change: FinCEN’s interim final rule (March 26, 2025) exempts entities created under U.S. law (domestic companies) and U.S. persons from BOI reporting under the Corporate Transparency Act (CTA). (See FinCEN alert and IFR.)- Who still must file: Reporting companies now principally include entities formed under the law of a foreign country that have registered to do business in a U.S.

State or Tribal jurisdiction by filing a document with a secretary of state or similar office — unless they qualify for another statutory exemption.- Deadlines (for foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had (per FinCEN) until April 25, 2025 to file initial BOI reports; entities that register on or after March 26, 2025 generally have 30 calendar days after their registration becomes effective. (Confirm current deadlines on FinCEN.)- Required filing method: BOI reports are filed electronically through FinCEN’s BOI E-Filing System.

Filers may (optionally) create FinCEN IDs to streamline submissions.- Data required: reporting-company identifying information, beneficial owners’ identifying information (name, date of birth, address, identification document and number or FinCEN ID), and company applicant info where applicable (review FinCEN guidance for the exact required fields and exceptions).- Exemptions and special rules: Multiple exemption categories remain in the CTA and implementing regulations (large operating companies, certain regulated entities, inactive entities, wholly owned subsidiaries, etc.).

FinCEN’s IFR also narrowed BOI reporting for foreign pooled investment vehicles in certain circumstances.- Security & fraud warning: FinCEN has warned of fraudulent solicitations seeking BOI and provides guidance on submitting data only through official FinCEN portals.State-specific guidance (for U.S. businesses / LLC founders):- Most U.S.-created LLCs and corporations: Generally exempt from BOI reporting to FinCEN under the March 2025 interim final rule.

However, U.S. entities should confirm their status (domestic vs foreign) based on where they were formed.- Foreign entities registered in a state: If a foreign company files a document with any state’s secretary of state (or similar office) to register to do business, that state filing is the trigger that may make the entity a FinCEN “reporting company.” Check the filing/registration records with the specific Secretary of State office(s) where you operate — the FinCEN IFR explicitly treats registration with a secretary of state (and territories) as the trigger.- State-by-state action items (general):

• If you formed your company in a U.S. State or territory: you are likely exempt — no FinCEN BOI filing required; retain documentation of formation and counsel review.
• If your company was formed outside the U.S. and you registered to do business in any U.S. State or territory: treat this as potentially reportable — verify registration date(s) and file within FinCEN deadlines.
• Use each state’s business search/filing portal to check registration effective dates (these dates determine filing timelines).Practical urgent-filing checklist (what to collect now):

Confirm entity classification

domestic (formed in U.S.) vs foreign (formed abroad). Retrieve formation/registration documents and filing dates.

Check FinCEN guidance and the IFR to confirm whether your entity is a reporting company or qualifies for an exemption.

If potentially reportable, collect required BOI for each beneficial owner and company applicant

full legal name, date of birth, current address, scanned identifying document (passport or driver’s license) and its number and issuing jurisdiction, and any existing FinCEN ID.

Choose filer and obtain secure methods for transferring PII (encrypted channels). Limit distribution to employees/advisors with need-to-know.

Create a FinCEN ID (optional) at

https://fincenid.fincen.gov and access BOI E-Filing System: https://boiefiling.fincen.gov6 . Draft, review, and certify the BOI report before submission; keep copies and maintain internal records of the filing date.7. Plan to update or correct BOI reports within the required timeframe if information changes (FinCEN requires updates and corrections within specific timeframes — verify current guidance).Recommended urgent next steps (for LLC founders / US business owners):- Step 1 (Immediate, within 24–72 hours): Verify entity formation jurisdiction and registration status. If foreign-formed and registered in the U.S., identify registration effective date(s).- Step 2 (If reportable): Gather BOI PII, create FinCEN ID (optional), and prepare to file on the BOI E-Filing portal. If you missed an April 25, 2025 deadline, check FinCEN guidance on late submissions and consider contacting counsel or a qualified filing service immediately.- Step 3 (If uncertain): Seek rapid advice from a compliance attorney or a BOI filing specialist. Prioritize secure transfer of PII and documented chain-of-custody for sensitive files.Suggested language for a short client notice or email: "Alert: Regulatory change — most U.S.-formed entities are currently exempt from BOI reporting under FinCEN’s March 26, 2025 interim final rule. If your company was formed abroad and registered to do business in any U.S. state or territory, you may still have a BOI filing obligation and urgent deadlines may apply. Contact us immediately to confirm status and prepare any required filings." Service & support offer (example CTA):- We provide urgent BOI filing support: entity classification review, exemption analysis, secure PII collection and e-filing, corrections and updates, recordkeeping. For immediate assistance, contact [contact info].