The Beneficial Ownership Information (BOI) reporting requirement is an anti-money laundering initiative enacted through the Corporate Transparency Act in 2021. The Financial Crimes Enforcement Network (FinCEN – pronounced “fin-sen”) is a division of the U.S. Treasury Department which will begin requiring small businesses including small CPA firms to report information on the “owner” of an entity beginning in 2024. Existing small businesses, formed before December 31, 2023, have one year to file – the filing deadline for these small businesses is January 1, 2025. Small businesses formed starting January 2024 or those that have a change in owner information throughout the year have 30 days to file. For more information see the AICPA’s resource landing page by visiting this link: AICPA BOI Resource Page. On the resource page, you will find many additional resources including AICPA’s FAQ sheet for firm practitioners which you can also access directly at this link: AICPA BOI FAQ Highlights.
Two bills have been introduced in U.S. Congress to delay this rule – H.R. 4035 and S. 2623, both titled the Protecting Small Business Information Act of 2023. These identical bills introduced in the U.S. House by Representative Patrick McHenry and introduced in the U.S. Senate by Senator Mike Rounds would delay the start date of the rule providing additional time for small businesses to learn about and better understand their new reporting requirements.
You can help secure cosponsors in both the U.S. House and U.S. Senate, to keep these bills moving. Reach out to your House of Representatives Member to ask them to cosponsor H.R. 4035, and to also reach out to your two United States Senators to ask them to cosponsor S. 2623.
Thank you for reaching out to your Senators and Representative to share the profession’s advocacy position on the BOI reporting rule and the legislation to delay the rule.