The vast majority of PPAI’s roughly 15,000 member companies are subject to a reporting requirement due by the end of this year.

  • The bipartisan Corporate Transparency Act, designed to thwart money laundering and other financial crimes, became law in 2021 and took effect at the beginning of this year.

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) began accepting beneficial ownership information – i.e., identifying information about the individual people who directly or indirectly own at least 25% of a company or exercise “substantial control” over the company – on January 1.

  • Failure to comply can trigger civil penalties (up to roughly $600 per day) and criminal penalties (up to two years’ imprisonment and a fine of up to $10,000).
  • Both individuals and corporate entities can be held liable for “willful violations.”

FinCEN issued notice on October 29 that it has extended deadlines for certain victims of five recent hurricanes to submit the required information.

Recently formed entities in affected areas, as designated by FEMA for individual or public assistance and by the IRS for tax filing relief, now have an additional six months to file or update the required BOI reports, or to correct their existing reports. Specifically, the six-month extension applies to the following:

  • Hurricane Beryl victims whose filing deadline was between July 4, 2024, and October 2, 2024
  • Hurricane Debby victims whose filing deadline was between July 31, 2024, and October 29, 2024
  • Hurricane Francine victims whose filing deadline was between September 8, 2024, and December 7, 2024
  • Hurricane Helene victims whose filing deadline was between September 22, 2024, and December 21, 2024
  • Hurricane Milton victims whose filing deadline was between October 4, 2024, and January 2, 2025


The Journal of Accounting reports that FinCEN also says it will work with any reporting company headquartered outside the disaster areas that must consult records located in one or more of them in order to meet the deadline.

Options For BOI Filing

While filing is free via online form, PDF or API, it’s not the easiest user experience, says Brian Grall, chief experience officer of Colorado-based distributor LogoMyBiz.com, a member of PPAI’s Government Relations Action Council.

  • Access the form by going to FinCEN’s BOI e-filing website and selecting “Get Started” at upper right or “File BOIR” at bottom left.

“The allegedly easy-to-fill-out online form is glitchy,” says Grall, adding that it took him about an hour to complete because it wasn’t immediately clear which fields were required. “I had to go back several times [because it’s] not always easy to find which areas might’ve been incomplete or required.”

Grall says he thinks he saw a confirmation screen once he finished and submitted the form online, but he has received no documentation. “I’m certain I never received anything email-wise that said it was complete,” he says, “and I haven’t received anything in the mail, either, that says it’s complete.”

Anyone the reporting company authorizes to act on its behalf, such as an owner, employee or third-party service provider (e.g., an attorney or accountant), may file a BOI report.

Fellow GRAC member Mary Jo Tomasini, MAS+, president of CE Promo, the No. 92 distributor in the PPAI 100, says her company’s legal counsel encouraged her to let them handle the filing – for a price, of course. After careful consideration, she says, the company chose that option.

“While there is an associated cost, we believe it’s the best decision to ensure that the process is handled correctly and that we remain compliant with all filing requirements,” Tomasini says. “The potential for daily fines or penalties, if something were to be missed or incorrectly filed, far outweighs the upfront cost of legal assistance. We want to avoid any complications and ensure everything is done right the first time.”

A half dozen lawsuits seeking to overturn the requirement are working their way through the courts, and the American Institute of Certified Public Accountants has submitted a letter to the Treasury Department asking to postpone enforcement until those are resolved.

Additionally, two bills have been introduced in Congress – one to repeal the rule and one intended to make filing easier – but neither has moved forward.

So, at least for now, BOI reporting is the law of the land. Here’s who needs to comply and when.

Small Businesses – Including Most PPAI Member Firms – Must File

Every business entity created by filing a document with a secretary of state or equivalent office must file a BOI report, unless it qualifies for one of 23 exemptions, which include but are not limited to financial services providers, insurance companies and certain tax-exempt entities.

Large operating companies that employ more than 20 full-time employees in the United States, maintain an operating presence at a physical office within the U.S. and filed a federal income tax return for the previous year demonstrating more than $5 million in gross receipts or sales are also exempt.

  • Small businesses with fewer than 20 employees and less than $5 million in gross receipts must file. This describes the vast majority of PPAI member firms.
  • Companies formed under the law of a foreign country that have registered to do business in the United States by the filing of a document with a secretary of state or any similar office also must file.
  • A domestic entity such as a statutory trust, business trust or foundation, as well as a foreign entity, must file only if it was created by the filing of a document with a secretary of state or similar office.

Information Required For Each Beneficial Owner

  • Name
  • Date of birth
  • Address
  • Number, issuer and image of a U.S. driver’s license, passport or other government-issued identification document.

While the information listed above is for each individual beneficial owner, the report also requires similar information about the company, such as its name and address. In addition, new companies created in 2024 must submit information about the individuals who formed the company.

Individuals who do the filing should be prepared to provide basic contact information for themselves as well, including name and email address or phone number.

Reporting Deadlines

For existing entities, the deadline to file is January 1, 2025. Newly formed companies have a specific window to file.

  • A company created or registered to do business before January 1, 2024, will have until January 1, 2025, to file its initial beneficial ownership information report.
  • A company created or registered on or after January 1, 2024, and before January 1, 2025, will have 90 days after receiving notice of its creation or registration to file its initial BOI report.
  • Reporting companies created or registered on or after January 1, 2025, will have 30 calendar days to file their initial BOI reports.

Filing is not an annual requirement. A report only needs to be submitted once, unless the filer needs to update or correct information. 

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