Like I said in my last post, now is the time to do CPE before everything gets crazy.
In CPE today I learned that the rules for BOI with FINCEN is not only that you must update the report or your FINCEN ID when ownership changes (which is what I initially thought was the only case), but when anything you gave them changes, such as your address, your driver’s license or passport expiring, etc.
Madness!
Absolute madness!
They’re not even hiding the fact now that they hate us all. And they hate small businesses most of all. Attempting to comply with this will be a nightmare for most small businesses with multiple owners. Every time an owner moves, every time their DL expires, they have 30 days to update their information with FINCEN. Or else.
If an owner dies, the new beneficial owner has 30 days to update the information. You know because when your parents die, that’s just what you want to deal with in the 30 days after. If the new owner is temporarily a trust or estate created on death, then the trustee may get dragged into it too.
What a mess.
As an aside, if you have multiple LLCs, you can obtain a FINCEN ID here. This will allow you to input the information required only once, and then just provide the ID for each LLC or company you own. Then when your ID expires or you move, you only have to update the information in one location. If you can remember that.
Good luck.