BOI reporting for businesses that operate multiple brands

For businesses operating multiple brands, BOI reporting obligations are tied to legal entities formed or registered by filing with state filing offices — not to trade names/DBAs. After FinCEN’s March 2025 interim final rule, domestic (U.S.-formed) entities are generally exempt from federal BOI filing; foreign entities registered to do business in the U.S. remain subject and must file BOI reports using FinCEN’s e-Filing system. For multi-brand businesses, the practical work is to inventory legal entities that underlie each brand, determine which entities (if any) meet FinCEN’s reporting-company definition, evaluate applicable exemptions (including subsidiary exemption), and then collect and file BOI data for each entity that is required to file. Keep strong documentation, consult counsel for complex ownership chains (including series LLCs and international ownership), and check state filing/formation rules where your brands are formed or registered.