Description
Need help with your FinCEN filing? Let Skepsis Legal handle it for you. We’ll help you gather the information you need to properly submit your FinCEN filing, and then we’ll make sure your report is submitted properly based on that information. This service works for both new filings, and required updates.
Read more about FinCEN reporting and its requirements in our blog post here.
Do I need this service if I already have a subscription with Skepsis Legal?
All of our subscriptions at the Business Basics level and higher include this service at no extra cost, so you don’t need to also sign up for this service with us. If you’re signed up for our Annual Registered Agent plan, then this service is not included, so you should sign up here to add a one-time filing to your account. If you’ve hired us to form your new LLC after January 1, 2024, then your initial report only is included with your LLC formation, and you’ll buy this service when you need to make updates.
What information will you need?
We’ll need information about your business, such as EIN, and information about your company’s beneficial owners. Note that determining beneficial owners can be tricky. A beneficial owner is a person who either: (i) exercises substantial control over a company; or (ii) holds 25% or more of a company’s ownership interests. In true federal government fashion, this isn’t as clear as it might sound at first blush. We know that LLC managers, presidents, CEOs, CFOs, COOs, and likely general counsel must be disclosed because the government rules say they exercise substantial control. But, other officers and employees might be included in this list.
Similarly, the test of individuals holding 25% or more of an ownership interest in a company is also not cut-and-dry. The regulations require companies to consider stock options, convertible instruments, contractual voting agreements among owners, and more.
Given the substantial grey area in these disclosure requirements and who may or may not be a “beneficial owner”, we highly recommend you work with your business attorney to make sure you’re properly identifying those individuals and entities. Our FinCEN BOI filing service does not include consultation with an attorney to help determine who your beneficial owners are, so if you’re not sure, book an attorney consultation before you sign up for the BOI filing service here.
Does this service include amendments?
This service covers a single filing, whether that’s your business’s initial filing, or an amendment. If something changes down the road, then you’ll need to file an update with FinCEN, which you can do on your own, or sign up again here for another filing by Skepsis Legal.
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