In addition to filing an initial BOI report, reporting companies must also update and correct information in their previously filed BOI reports. Individuals who obtain FinCEN identifiers must also update and correct information previously reported to FinCEN. This chapter discusses what to do when there are changes to or inaccuracies in reported information in the following sections:
6.2 What should I do if I learn of an inaccuracy in a report?
6.3 What should my company do if it becomes exempt after already filing a report?
UPDATED REPORTS
Required when there is a change to previously reported information about the reporting company itself or its beneficial owners.
Updated reports due within 30 calendar days after a change occurs.
If there is any change to the required information about your company or its beneficial owners in a BOI report that your company filed, your company must file an updated BOI report no later than 30 days after the date on which the change occurred. The same 30-day timeline applies to changes in information submitted by an individual in order to obtain a FinCEN identifier. A reporting company is not required to file an updated report for any changes to previously reported personal information about a company applicant.
The following are some examples of changes that would require an updated BOI report:
- Any change to the information reported for the reporting company, such as registering a new DBA.
- A change in beneficial owners, such as a new Chief Executive Officer, a sale that changes who meets the ownership interest threshold of 25 percent, or the death of a beneficial owner.
Note: When a beneficial owner dies, resulting in changes to the reporting company’s beneficial owners, report those changes within 30 days of when the deceased beneficial owner’s estate is settled. The updated report should, to the extent appropriate, identify any new beneficial owners.
- Any change to a beneficial owner’s name, address, or unique identifying number provided in a BOI report.
Note: If a beneficial owner obtained a new driver’s license or other identifying document that includes the changed name, address, or identifying number, the reporting company also would have to file an updated beneficial ownership information report with FinCEN, including an image of the new identifying document.
Special rule: Keep in mind the update requirement related to the special reporting rule for a minor child. When a beneficial owner that was a minor child reaches the age of majority, you must file an updated BOI report, identifying the individual as a beneficial owner and, if warranted, replacing their parent or legal guardian’s information with their own.
Note: There are no penalties for filing an inaccurate BOI report provided it is corrected within 90 calendar days of when it was filed.
If your company filed a BOI report and later qualifies for an exemption from the reporting requirements, your company should file an updated BOI report to indicate that it is newly exempt from the reporting requirements. Refer to section 1.2 of this Guide for information on exemptions
Updated BOI reports should be filed electronically though the secure filing system. An updated BOI report for a newly exempt entity will only require that: (1) the entity identify itself; and (2) check a box noting its newly exempt status.