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The UACPA Supports Comment Letter Calling for an Extension and Expansion in Beneficial Ownership Reporting Requirements

November 03, 2023

The UACPA has joined AICPA and dozens of other state CPA societies to ask the Financial Crimes Enforcement Network (FinCEN) to extend and expand the deadline for beneficial ownership information (BOI) reporting requirements, specifically for Reporting Companies Created or Registered in 2024.

Effective January 1, 2024, existing companies, companies created or registered before January 1, 2024, will have one year, through January 1, 2025, to file their initial BOI reports. New companies, companies created or registered on or after January 1, 2024, will have 30 days to file their initial BOI reports. If there are inaccuracies in the initial BOI report filed or companies have a change in information, such as change in residential address or percentage of ownership, they will have 30 days to report changes or correct the inaccuracies.

The BOI reporting requirement is an anti-money laundering initiative enacted through the Corporate Transparency Act (CTA) in 2021, which mandates that BOI information is reported to (FinCEN).

In a comment letter, sent October 30, 2023, the profession specifically recommends that FinCEN extend the deadline from the proposed 90 days to one year and expand the applicability of the deadline to include not only new entities created in 2024 but ALL entities created thereafter, as well as entities making updates or corrections to their original filings.

Lack of awareness is highlighted in the letter, citing that most businesses are not familiar with the new BOI regulation, despite the campaigns put in place to inform them. The time and financial burdens on small businesses were also mentioned as a potential result of not instituting the recommended changes. The comment letter also hopes to avoid the steep taxpayer penalties that could accompany unawareness of the new reporting requirements.

“The UACPA has joined the AICPA and other state societies to call for improving BOI reporting requirements,” said CEO Susan Speirs, “We believe that extending and expanding these reporting requirements will have a beneficial impact on taxpayers, small businesses and our members, who are serving as their trusted advisers.”