FINAL RULE ON BOI (Beneficial Ownership Information)
Published: September 21st, 2026
On August 11th, 2026, the Financial Crimes Enforcement Network (FinCEN) announced their “final rule” of the BOI reporting requirements. FinCEN made the BOI reporting permanent that the U.S. government will remove the requirement of U.S. companies and U.S. persons to report the beneficial ownership information to the organization (“BOI reporting”) to the organization under the Corporate Transparency Act.
FinCEN also reported with the final rule that it will delete previously reported information by U.S. persons from the beneficial ownership information database.
The final rule included the exemptions included in the interim final rule. Below are the exemptions included as published on FinCEN’s website (www.FinCEN.gov/BOI).
- Exemption of U.S. persons who obtained FinCEN IDs from any obligation to update/correct information
- Exemption from foreign pooled investment vehicles registered in the United States from reporting the beneficial ownership information of the U.S. persons who control the entity
- Eliminates requirement for foreign companies to report U.S. Persons to report company applicants.
Although domestic companies and U.S. Persons are fully exempt from beneficial ownership information reporting, certain foreign entities and non-U.S. persons are not exempt from reporting. See U.S. legal advice on this.
New York Beneficial Ownership Information Reporting
As of January 1st, 2026, “The New York’s LLC Transparency Act” requires LLCs authorized to do business in New York but formed under a foreign country to report under the NY LLC Transparency Act, which is separate from the Federal BOI reporting requirement.
For more information on the NY BOI disclosure reporting click the link below
Beneficial Owner Disclosure | Department of State
For more information on the FinCEN beneficial ownership information reporting final ruling click here .
The above information is of a general nature only and should not be relied upon for specific situations. The information is to alert clients to bring this topic up as needed to their independent legal counsel.
Always seek professional US legal advice when it comes to BOI reporting as Marlies Y Hendricks CPA PLLC does not practice in this area.
Call Marlies Y Hendricks CPA PLLC at either 716-694-3500 or 910-769-8730 as required to set up an appointment for accounting, tax or cross-border CPA tax advice as a Certified Public Accountant.
