BOI compliance support for multi-founder SaaS startups

Subject: Urgent BOI Compliance Update for Multi-Founder SaaS StartupsDear Founder, The rules around Beneficial Ownership Information (BOI) reporting have changed significantly, and it's crucial for your multi-founder SaaS startup to stay compliant. Here's what you need to know: Federal BOI Relief for U.S. Companies Great news for most U.S.-formed companies! FinCEN's Interim Final Rule (March 26, 2025) has exempted U.S. entities and U.S. persons from federal BOI reporting under the Corporate Transparency Act (CTA). This means many U.S. startups are no longer required to file BOI reports with FinCEN. State-Level Requirements Are Still Critical While federal obligations have eased, state-specific transparency laws are emerging. For example, the New York LLC Transparency Act (NYTA), effective January 1, 2026, requires LLCs (formed in NY or doing business there) to file Beneficial Ownership Reports. Existing NY LLCs have until January 1, 2027, to comply. Other states are also considering similar legislation. You must check your state(s) of formation and operation! Immediate Actionable Checklist for Founders: 1. Inventory Your Entities: List all your legal entities and their jurisdictions. 2. Map Control & Ownership: Update your capitalization table and identify individuals with ≥25% ownership or 'substantial control'. 3. Check State Rules: Verify BOI obligations in your state(s), especially if you have New York nexus as an LLC. 4. Collect BOI Data: Gather necessary information (name, DOB, address, ID) for identified beneficial owners if state filing is required. Guidance on SAFEs, Convertible Notes, and Options: Generally, unexercised options or unconverted SAFEs/convertible notes are not reported as current ownership. However, if these instruments grant present control rights (e.g., board seats, veto power), the individuals holding these rights should be considered potential beneficial owners. Always assess individuals with binding governance or control rights, even if their economic ownership is below 25%. Don't Risk Penalties: Willful failure to comply with reporting requirements can lead to significant civil and criminal penalties at both federal (for foreign entities) and state levels. Next Step: Consult Legal Counsel We strongly recommend engaging legal counsel to confirm your specific state-by-state obligations and to establish an internal process for ongoing monitoring and updates. Stay compliant, [Your Company Name/Team]