BOI compliance handoff to assistants

Important Update: BOI Compliance Handoff to Assistants

Dear US Business Owners and LLC Founders,

A significant change has occurred in Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA). On March 26, 2025, FinCEN issued an Interim Final Rule (IFR) that exempts most U.S. domestic reporting companies and U.S. persons from federal BOI reporting requirements. The focus is now primarily on foreign reporting companies registered to do business in the U.S.

While this update simplifies federal compliance for many, it underscores the importance of having clear internal processes for managing beneficial ownership information. Even if your business is exempt from federal reporting, state-level requirements (like New York's LLC Transparency Act for foreign LLCs) are emerging, and robust internal procedures are essential for future readiness, data security, and auditability.

Key Takeaways for Your Business:

• Federal Exemption: Most U.S.-formed entities and U.S. persons are now exempt from federal BOI reporting to FinCEN.
• Foreign Entities Still Report: Foreign reporting companies registered in the U.S. must still comply with FinCEN's BOI reporting, with new deadlines.
• State-Level Rules: Be aware of state-specific laws, such as New York's LLC Transparency Act, which requires foreign LLCs doing business in NY to file beneficial ownership disclosures starting January 1, 2026.
• Delegate with Confidence: FinCEN allows authorized individuals (employees, owners, or third-party providers) to file BOI reports. Implementing a clear Standard Operating Procedure (SOP) for delegating these tasks ensures accuracy, security, and proper recordkeeping.

Actionable Steps for Delegating BOI Compliance:

1. Formalize Authorization: Clearly designate who can file on your behalf with a written authorization.
2. Secure Data Collection: Establish a process for securely collecting and verifying beneficial owner information and identification documents.
3. Recordkeeping: Maintain meticulous records of authorizations, verification steps, and submission confirmations (e.g., FinCEN acknowledgments).
4. Data Security: Implement strong data security measures and access controls for all BOI-related information.

For a comprehensive guide on navigating these changes and setting up a robust BOI compliance handoff process, including detailed checklists and templates, read our full blog post: [Link to Blog Post]

You can also find official guidance and resources directly from FinCEN:

• FinCEN BOI FAQs: https://www.fincen.gov/boi-faqs
• FinCEN BOI Main Page: https://www.fincen.gov/boi

Stay compliant and secure!

Sincerely,
[Your Company Name]