By now, you’ve probably already heard about the new federal filing requirement under the Corporate Transparency Act which mandates that virtually every small business registered in the United States must file a beneficial ownership information (BOI) report with the Financial Crimes Enforcement Network (FinCEN).

If you haven’t already filed your report, what are you waiting for? File your BOI report today. If you’ve taken the initiative and the report is done-and-dusted, you’re ahead of most. Just remember: the BOI report isn’t a one-and-done corporate filing. You may need to file an update now and then with FinCEN. When exactly should you file an update? When any of these bits of information change, you must file an update within 30 days:

1. Change of Company Address
   Has your company moved offices? Has your suite number changed? Did your storefront relocate down the block to get better foot traffic? If you answered yes to any of these questions, or if for any reason your company address is different than when you first filed your BOI report, you must file an update.
2. Change in Beneficial Owners
   If you’ll recall, a “beneficial owner” includes any individual who, directly or indirectly, exercises substantial control over a company. The threshold for substantial control is defined by whether an individual meets any of these four general criteria:
   – Is a senior officer;
   – Is an important decision-maker;
   – Has authority to appoint or remove officers or a majority of directors; or
   – Has any other form of substantial control over the reporting company.
   No ownership interest in the company is required. You might not think you “own” the company and therefore can’t be classified as a beneficial owner, but if you satisfy one or more of the above criteria, you must disclose your relationship. Similarly, if any of these beneficial owners have left the organization or if new ones have been brought on, you must file an update to your BOI report.
3. Change of Owner’s Name, Address, or Identification
   Maybe you recently got married and now have a new last name. Maybe you moved houses or upgraded to a new condo. Maybe your state or government ID has new or updated information. If so, you must file an update.

Financial crimes are serious business and the new FinCEN requirement to file beneficial ownership information is meant to provide law enforcement, national security entities, and financial institutions with the most recent and up-to-date information on the individuals who own or control businesses in the United States. Don’t neglect your filing requirements. If you need help, simply say hello and ask Propel!