This new requirement is both significant and broadly applicable to our clients with substantial penalties for non-compliance. We estimate that in our firm’s client base, there are likely between 1000-1500 BOI reporting requirements alone. While the reporting itself is not complex, the specific guideline around this new process is nuanced. Therefore, we want to be proactive in helping you generally understand the requirements.
Who Needs to File BOI Reports?
If you have a business entity (Corporation, LLC, partnership, trust) that operates in the US or has any assets (including cash, real estate, etc.) it is a safe assumption that these requirements apply to you. There are some limited exceptions to the reporting that exist, and we are happy to answer those questions for you or you can go to the FinCen site to access FAQs.
As for filing your BOI Reports, you have 2 options:
- Self-filing: You may choose to file your BOI Report(s) yourself, and we encourage you to do this if you feel comfortable doing so! As mentioned, the form itself is not complicated, and you can file for free on the FinCen website. Please be aware, however, that if you choose this option Anthem Strategists cannot provide you with advice regarding your filing requirements, who is a beneficial owner of your business, etc. We also cannot review forms you have self-filed and provide advice around these. We have made this decision based on the advice of industry experts and our liability insurance carrier, as well as to manage demand on our firm’s resources. We can only provide specific assistance on these forms to the extent you have hired us for these services as described under option 2.
- Anthem Strategist BOI Filing services: Our firm can file your BOI Reports on your behalf. This would include gathering of information, determination of beneficial owners based on the information provided, and preparing and submitting the necessary reports for FinCEN. Because this is a brand-new compliance requirement, it was not included in any prior agreements that we may have made with you and therefore pricing for this service will be as follows:
- Base Fee (includes 1 Beneficial Owner) for Domestic/US Owned Entities – $500.00
- Base Fee (includes 1 Beneficial Owner) for Foreign/Non-US Owned Entities – $750.00
- Fee for Each Additional Domestic/US Beneficial Owner – $150.00
- Fee for Each Additional Foreign/Non-US Beneficial Owner – $250.00
If you’d like us to handle this, get in touch with us ASAP.
What Happens Next?
You will receive an opt in/opt out document through SafeSend Returns the week of September 16th, 2024. This document will allow you to tell us if you would like us to file for you or if you plan to file for yourself. Please remember that it is crucial not to ignore this requirement. The fines are steep if you do not register. You will also need to remember to resubmit any changes regarding your company ownership including address changes for individual owners. You will need to manage this on your own and refile the form again with FinCen for every business that you submitted for. If we file for you and you have changes you will simply need to communicate those changes to us. We will be able to easily do this with our BOI software.
Again, if you need clarification on anything we touched on please feel free to reach out to us today.
