Step-By-Step Guide to File Your Beneficial Ownership Information Report

Most businesses will have to file a Beneficial Ownership Information Report (BOIR) under the Corporate Transparency Act, which went into effect on January 1, 2024.

To comply with the new requirement, you’ll need to file your BOIR by its designated deadline. For existing companies, the deadline is January 1, 2025, while new companies formed in 2024 have 90 days to submit their report.

The good news is that completing the necessary paperwork is easy, free, and takes less than 15 minutes provided you have the information you need readily available. If you’ve confirmed your eligibility and are prepared to file and submit your BOIR on your own, keep reading.

How to file your Beneficial Ownership Information Report

You can file your Beneficial Ownership Information Report one of three ways:

• The first method involves a PDF that is downloaded to your computer, filled out, and submitted via the FinCEN online portal. This allows you to fill out the BOIR at your own leisure.
• The second filing method asks you to complete and submit your BOIR directly on the FinCEN website.
• The third method requires you to contact FinCEN for Application Programming Interface (API) information.

This article is going to do a deep dive on the second filing method, which means you’ll fill out your BOIR online within the FinCEN portal.

Accessing the BOIR

First things first, you’ll need to navigate to the FinCEN website. Once there, you’ll click on the icon that says “Beneficial Ownership Information”.

On the right side of the page, you’ll click the first link under “File” that says “File a report using the BOI E-Filing System”.

Underneath where it says “Beneficial Ownership Reporting”, click on the button that says ‘Get Started’.

Next, you’ll be asked how you want to file your BOI Report. Under the section titled “File Online BOIR”, click the blue button titled “Prepare and Submit BOIR”.

At this point, you’ll be able to start filling your BOIR. The questions are organized into different categories, each accessible through tabs. You can easily switch between tabs at any time. However, it's crucial to note that you cannot save your BOIR and return to it later – it must be completed in one session.

Filling out the BOIR

It’s important that you fill out the entire report with all necessary information. Fields denoted with an asterisk (*) are mandatory for all companies filing the report.

Tip: If you need extra help filling out your BOIR, you can click the gray banner that says “Need help?” above each set of questions for a more detailed explanation.

Filing Information

Type of filing – Select the type of filing. If this is your first time filing a BOIR, choose "a. Initial report." If you are correcting inaccurate information from a previous BOIR, select “b. Correct prior report.” For updates to an existing BOIR, choose “c. Update prior report.”.

Date prepared – Today’s date should be autofilled, but if not, you’ll need to fill it in.

Part 1: Reporting Company Information

Request to receive FinCEN ID – Indicate whether you would like your company to be assigned a unique FinCEN Identifier. It’s strongly advised to check this box, as obtaining a FinCEN ID is free and will likely become an important identifier for your business, similar to an EIN.

Foreign pooled investment vehicle – The majority of business owners do not need to worry about this. However, if your reporting company is classified as a foreign pooled investment, only one beneficial owner who holds substantial control over the entity needs to be reported. If multiple individuals exert substantial control over the entity, the entity should provide information about the individual with the highest authority in strategic management.

Legal and alternate names – List your company name exactly as it appears on records, as well as any fictitious names your company may be operating under.

Form of identification – Specify whether you prefer to provide your business's EIN or SSN/ITIN, and then enter it in the corresponding box. You can disregard the country/jurisdiction box in this section, as it is only relevant for foreign tax IDs.

Jurisdiction of formation or first registration – Select the country your company was formed in.

Current U.S. Address – Fill out your company's current address details, including the street, city, state, and ZIP code. This address should reflect the primary location in the U.S. where the reporting company conducts its business. If you are remote and prefer not to use your home address, you can lease an affordable commercial business address through VPM’s TruLease service.

Existing reporting company – Check this box if your company was created on or before January 1, 2024. If it was registered after this date, leave it blank. Reporting companies that check this box are not required to report any company applicants and may proceed to Part 3.

Part 2: Company Applicant Information

Company applicant FinCEN ID – If you already have a FinCEN ID, you can enter it here and skip fields 19 through 33. If not, you’ll need to provide all of the information asked about company applicants in Part 2.

Legal name and date of birth – Enter your legal name and date of birth as it appears on records.

Current address – You can provide either your company address or residential address, but you’ll need to be sure to specify which one it is. Be sure to include the street name, city, state, country, and zip code.

Form of identification and issuing jurisdiction – Choose which form of identification you’re providing: a state issued driver’s license, state/local/tribe-issued ID, U.S. passport, or foreign passport. You’ll also need to provide a document number, jurisdiction information, and a clear photo of the qualifying document.

Part 3: Beneficial Owner Information

Beneficial Owner FinCEN ID – Similar to the last section, you may enter a FinCEN ID if you have one, skipping fields 37 through 51. If not, leave this blank and proceed to the next question.

Exempt entity – If the beneficial owner's ownership in the reporting company is only through exempt entities, check this box. Then, you'll need to provide the legal name of the exempt entity in the field that appears.

Legal name and date of birth – Enter your legal name and date of birth as it appears on records.

Residential address – Be sure to include the street name, city, state, country, and zip code. If you’re in need of a long-term residential address, consider VPM’s TruResidence service.

Form of identification and issuing jurisdiction – Choose which form of identification you’re providing: a state issued driver’s license, state/local/tribe-issued ID, U.S. passport, or foreign passport. You’ll also need to provide a document number, jurisdiction information, and a clear photo of the qualifying document.

Submit BOIR

Once you’ve filled out your full name, email address, and checked the box stating you are authorized to file the BOIR on behalf of the reporting company, you’re ready to submit.

For quality assurance, you may want to go back over your answers again to make sure nothing was missed. Once submitted, you’ll have the opportunity to download a copy of your report.

Staying on top of updates

In order to ensure compliance and maintain accurate records, you’ll need to stay up-to-date on your BOIR. Companies are required to update their BOIR within 30 days of any changes to the company or beneficial owner information.

So, what changes necessitate an update? Here are a few examples:

• Registering a new DBA – If your company decides to adopt a new "Doing Business As" or trade name, it's time for an update.
• Change in beneficial owners – This includes scenarios like welcoming a new CEO to the team.
• Sale impacting ownership interest – If a sale occurs that alters who holds at least 25% ownership interest, your BOIR requires an update.
• Death of a beneficial owner – In the event of a beneficial owner's passing, this information needs updating.
• Changes to beneficial owner details – Any modifications to a beneficial owner's name, address, or unique identifying number as provided in the BOIR also require updating.

Once the initial report is filed, there's no need to update the company applicant information unless you encounter any of the above scenarios.

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Equipped with this step-by-step guide, filling your Beneficial Ownership Information Report should be easy. However, if you need a residential address for your BOIR, VPM’s TruResidence service offers the perfect solution. Ensure privacy and compliance by obtaining a secure residential address today!