What BOI Resources Exist for Bank Customers?
By Scott Birrenkott
Earlier this year, we published an article discussing the various rulemakings undertaken by the Financial Crimes Enforcement Network (FinCEN) to implement the requirements of the Corporate Transparency Act (CTA). One of those requirements applies to companies that must report (reporting companies) beneficial ownership information (BOI). While this rule doesn’t place any requirements upon banks, many reporting companies have come to their banks with questions. FinCEN has created numerous resources which reporting companies may find helpful and banks can direct their customers toward when they have questions.
Most recently, FinCEN issued a notice to customers of financial institutions about the BOI reporting requirements. This notice should answer any remaining questions reporting companies might have. Should they still have questions, there are additional resources banks can refer them to. For example, FinCEN maintains numerous resources on its website. The website includes frequently updated FAQs, information subscriptions, access to the filing system and filing instructions, a brochure introduction to BOI reporting, BOI reference guide, and BOI videos.
One particularly helpful resource is FinCEN’s small entity compliance guide. This guide includes 57 pages of information for reporting companies. It includes sections outlining how to determine whether a company must report, how to identify who a beneficial owner is, the specific information which must be reported, and explicit instructions for when and how a BOI report must be filed.
Additionally, WBA has created resources for banks to further understand the differences between the rules, as well as customer-facing resources to better help banks work with reporting companies who might have questions. These resources can be found on the WBA website under the compliance section of the Best Practices Library.
Additional information regarding the CTA and specifics surrounding FinCEN’s rule are in the March/April 2024 edition of the Wisconsin Banker. If you have any questions, please contact WBA legal at wbalegal@wisbank.com or call us at 608-441-1200.
Birrenkott is the WBA director – legal
