Let’s Talk Beneficial Ownership Information Reports – Sharing My Experience

February 27, 2024

You may be seeing a flurry of information on FinCEN’s newest requirement – the filing of the BOIR – the Beneficial Ownership Information Report. I recently filed mine and wanted to share my experience. If you don’t have time to read this whole blog article – *the bottom line is use the “online filing” option for your filing.*

First, you will need to determine if your business must file a BOIR. Here is the information you need to review to determine this: https://www.fincen.gov/boi-faqs Basically, you are off the hook if your business is in certain industries, is a 501(c)(3) non-profit, if you have 20 or more employees in the U.S., if your gross revenue receipts are more than $5M, etc. But if you are a small business, like CLEAResources, you may be required to file this new report so be sure to add it to your regular compliance reporting requirements.

CLEAResources operates in the U.S. with less than 20 full-time employees and less than $5M in gross revenue, and it does not fall into any of the industry exemptions, so I had to file a BOIR for my woman veteran-owned small business. No problem, right? I went to the FinCEN site and had two choices: a) online filing and b) pdf download-then-fill-and-upload. Since I have Adobe Acrobat, I opted for b. I downloaded the form, selected “fill and sign” in Acrobat tools, and proceeded to fill in the form. Once the form was filled out, I saved it, closed it, and went back to the FinCEN site to upload the form. That’s when the fun began.

The completed pdf would not upload to the FinCEN site. It was repeatedly rejected, and I kept getting error messages, so I had to troubleshoot. I finally figured out that the maximum size for the pdf upload was 5MB. No problem, right? I will just resize my pdf and try to upload it again. Not so fast – the security on the downloaded pdf does not permit the user to reduce the size of the pdf, and when fully completed, the file size is larger than the system will accept. End result? I had to make the filing “online.” At least I had all the right information assembled at that point. 

All in all, this form was not that burdensome, especially in comparison to say, SAM.gov registration. However, my company does not have many beneficial owners to list. This filing will be a more significant burden for other small businesses that have multiple investors, are family-owned and operated, granted significant equity to others, or have multiple founders or a governing board. As always, CLEAResources is here to help you with corporate compliance. If you need support or assistance with filing your BOIR, please don’t hesitate to reach out for help. I have seen law firms and accounting firms offer their assistance with this new requirement, but before you pay someone for advice or to make the filing for you, take a good look at the form to determine if you really need to incur that expense. You’ve read this far because you are interested in what I think – and I think “you got this!”

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