The Financial Crimes Enforcement Network (“FinCEN”) is proposing to amend the beneficial ownership information (“BOI”) reporting rule (the “Reporting Rule”) to extend the filing deadline for certain companies to file their BOI reports. Under this proposed amendment to the Reporting Rule, reporting companies created or registered on or after January 1, 2024, and before January 1, 2025, would have 90 days to submit their initial BOI reports, instead of 30 days. Reporting companies formed on or after January 1, 2025, would continue to be required to submit their initial BOI reports within 30 days.

According to FinCEN, a 30-day timeframe for initial reports would provide sufficient time for reporting companies to resolve various issues after initial creation, including obtaining necessary information and identifying their beneficial owners with sufficient time to file an initial report. FinCEN recognizes that there are many aspects of the Reporting Rule that newly created or registered entities will need to navigate, including whether the new legal entity falls under the definition of “reporting company” or qualifies for an exemption, the meaning of “beneficial owner” under the rule, and the application of other key terms and requirements.

It bears note that all other reporting deadlines under the BOI Final Rule remain unchanged, other than for newly created or newly registered business entities during 2025.