The short answer: No.
What is a BOIR?
A BOIR is also known as a Beneficial Ownership Information Report. While a beneficial ownership report (BOIR) is typically filed once upon an entity’s formation or registration, there are specific circumstances that require updates. Here are some common scenarios:
Change in Beneficial Ownership: If there’s a significant change in the individuals who ultimately own or control the entity, such as:
- A new beneficial owner acquiring a controlling interest.
- An existing beneficial owner relinquishing their interest.
- A change in the ownership structure of a beneficial owner.
Change in Beneficial Owner Information:
- Legal Name: Changes to the legal name of a beneficial owner, such as due to marriage, divorce, or other legal actions.
- Address: Any changes to the residential or mailing address of a beneficial owner.
- Date of Birth: Updates to the date of birth of a beneficial owner.
- Citizenship or Nationality: Changes in the citizenship or nationality of a beneficial owner.
- Taxpayer Identification Number (TIN): Updates to the TIN of a beneficial owner, including changes to the type of TIN (e.g., individual, corporation) or the number itself.
Change in Company Information: If there’s a change in the entity’s basic information, such as:
- Legal Name: Changes to the legal name of the reporting company.
- Address: Updates to the company’s address.
- Structure: Changes in the company’s organizational structure (e.g., from a corporation to a partnership).
- Jurisdiction: A change in the entity’s jurisdiction.
Regulatory Changes: New laws or regulations may require additional reporting or updates to existing BOIR reports. This could include:
- Changes in the definition of a beneficial owner.
- Increased reporting thresholds.
- New requirements for certain types of entities.
When must you file an updated Beneficial Ownership Information Report (BOIR)?
You must file an updated Beneficial Ownership Information Report (BOIR) within 30 calendar days of any change in information reported about your company or its beneficial owners. This obligation continues for the duration of your company’s status as a reporting entity. Failure to comply with these updating requirements may result in penalties.
Note: It’s essential to consult the specific requirements and guidelines provided by the relevant regulatory authority (e.g., Financial Crimes Enforcement Network (FinCEN) in the United States) to ensure compliance with all applicable rules regarding BOIR updates.
