The Financial Crimes Enforcement Network (FinCEN) has published a 56-page Small Entity Compliance Guide[1] to aid small businesses in adhering to the beneficial ownership information reporting requirements introduced by the Corporate Transparency Act (31 U.S.C. 5336).

The guide contains the following five chapters:

• Chapter 1. Does my company have to report its beneficial owners?

• Chapter 2. Who is a beneficial owner of my company?

• Chapter 3. Does my company have to report its company applicants?

• Chapter 4. What specific information does my company need to report?

• Chapter 5. When and how should my company file its initial BOI report?

• Chapter 6. What if there are changes to or inaccuracies in reported information?

The guide concludes with an index in Appendix A, which outlines various components of the reporting rule. The PDF includes hyperlinks to direct the reader to the corresponding sections for ease of navigation.

Some key items in the guide include:

• Checklists to determine entity qualification for each of the 23 exemptions from having to file the reports

• Checklists to determine if someone has substantial control or an ownership interest in a covered entity that requires reporting as a beneficial ownership interest

• Checklists to determine if an otherwise beneficial owner meets one of the five exceptions from the beneficial owner definition

• Other information related to the reporting of company applicants, information that must be provided, dealing with changes in information and later reporting, when reports must be filed and how such reports will be filed.

[1] Small Entity Compliance Guide, Financial Crimes Enforcement Network, Version 1.0, September 2023, https://www.fincen.gov/sites/default/files/shared/BOI_Small_Compliance_Guide_FINAL_Sept_508C.pdf (retrieved September 23, 2023)