Beneficial Ownership Information

Commercial Banking Customers

An Important Announcement from Firstier Bank

We wanted to make you aware of a new requirement from the U.S. Department of the Treasury to file beneficial owner information with the Financial Crimes Enforcement Network (FinCEN)

Beginning on January 1, 2024, many companies in the United States will have to report information about their beneficial owners, i.e., the individuals who ultimately own or control the company. They will have to report the information to FinCEN, a bureau of the U.S. Department of the Treasury.

Please review the following information to determine if you are required to report, when and how.

WHO

Companies required to report are called reporting companies. Reporting companies may have to obtain information from their beneficial owners and report that information to FinCEN.

Your company may be a reporting company and need to report information about its beneficial owners if your company is:

1. A corporation, a limited liability company (LLC), or was otherwise created in the United States by filing a document with a secretary of state or any similar office under the law of a state or Indian tribe; or
2. A foreign company and was registered to do business in any U.S. state or Indian tribe by such a filing.

WHAT

Beneficial ownership information is information about an entity, its beneficial owners, and, in certain cases, its company applicants. The person submitting beneficial ownership information to FinCEN must certify that the information is true, correct, and complete. The specific information required is described in these instructions and in Chapter 4 of FinCEN’s Small Entity Compliance Guide. To learn more about how to identify beneficial owners, review Chapter 2 of FinCEN’s Small Entity Compliance Guide. To learn more about the reporting requirements for and how to identify company applicants, review Chapter 3 of FinCEN’s Small Entity Compliance Guide.

WHEN

FinCEN began accepting BOIRs electronically through its secure filing system January 1, 2024.

• If your company was created or registered prior to January 1, 2024, you will have until January 1, 2025, to report BOI.
• If your company was created or registered on or after January 1, 2024, and before January 1, 2025, you must report BOI within 90 calendar days after receiving actual or public notice that your company’s creation or registration is effective, whichever is earlier.
• If your company was created or registered on or after January 1, 2025, you must file BOI within 30 calendar days after receiving actual or public notice that its creation or registration is effective.
• Any updates or corrections to beneficial ownership information that you previously filed with FinCEN must be submitted within 30 days.

Where to Report Beneficial Ownership Information

Reporting companies will have to report beneficial ownership information electronically through FinCEN’s website: https://www.fincen.gov/boi. The system will provide the filer with confirmation of receipt once a completed report is filed with FinCEN.
*Please note: your banker will NOT be able to assist with this process.

For more information on reporting beneficial owner information, please download An Introduction to Beneficial Ownership Information Reporting from the U.S. Treasury or visit: https://www.fincen.gov/boi..

For more information on what FinCEN collects compared to what financial institutions collect regarding beneficial owner information, please see the Notice to Customers: Beneficial Ownership Information Reference Guide or visit: https://www.fincen.gov/boi.