PART 1 – CLIENT LETTER (Cover Email or PDF)

Subject: Action Required – Beneficial Ownership Information Reporting Under the Corporate Transparency Act

Dear [CLIENT CONTACT NAME],

This letter provides an overview of new federal Beneficial Ownership Information (“BOI”) reporting obligations under the Corporate Transparency Act (CTA). Your entity, [CLIENT ENTITY NAME], appears to be [IN-SCOPE/EXEMPT – confirm below]. Please review the enclosed checklist and instructions.

Key Points

• Filing Deadline: Entities formed before January 1, 2024 must file by January 1, 2025. Entities formed on or after January 1, 2024 must file within 90 calendar days of formation (reduced to 30 days after January 1, 2025).
• Reporting Portal: BOI reports must be filed through FinCEN’s secure system at [https://boiefiling.fincen.gov/].
• Information Required: Legal name, trade names, principal address, jurisdiction, TIN/EIN, and information about beneficial owners and company applicants (if applicable).
• Penalties: Civil penalties up to $500 per day and potential criminal penalties for willful failures.

Please complete the attached Beneficial Ownership Checklist and return it by [DATE]. Our team will then prepare or review the BOI report as instructed.

Sincerely,
[LAW FIRM/ADVISOR NAME]
[CONTACT INFORMATION]

PART 2 – BENEFICIAL OWNERSHIP CHECKLIST

Section A – Entity Information

• Legal Name: [ ]
• DBA/Trade Names: [ ]
• Jurisdiction of Formation: [ ]
• TIN/EIN: [ ]
• Principal Address: [ ]

Section B – Exemption Analysis

• Does the entity employ more than 20 full-time employees in the U.S.? [Yes/No]
• Does the entity have more than $5M in gross receipts/sales reported in the U.S.? [Yes/No]
• Does the entity have a physical office in the U.S.? [Yes/No]
• Is the entity a regulated entity (e.g., bank, credit union, insurance company, SEC reporting issuer)? [Yes/No]
• If exempt, identify exemption category and supporting documentation.

Section C – Beneficial Owners (25% ownership or substantial control)

For each beneficial owner, provide:
- Full Legal Name
- Date of Birth
- Residential Address
- Identifying Number (e.g., driver’s license, passport)
- Issuing Jurisdiction
- Copy of identification document (secure upload link provided separately)

Section D – Company Applicants (if entity formed on/after Jan 1, 2024)

• Applicant 1: [ ]
• Applicant 2 (if applicable): [ ]
• Title/Role: [ ]
• Formation Date: [ ]

Section E – Filing Instructions

• Will we prepare and submit the BOI report on your behalf? [Yes/No]
• Point of contact for questions: [ ]
• Authorized signer for certifications: [ ]

PART 3 – INTERNAL WORKFLOW GUIDE (For Advisors)

1. Intake: Confirm engagement terms, collect checklist, and validate IDs securely.
2. Review: Assess exemption criteria and completeness of beneficial owner data.
3. Preparation: Populate FinCEN BOI filing system. Double-check accuracy before submission.
4. Submission: File BOI report, obtain confirmation number, and store securely.
5. Post-Filing: Provide confirmation to client and schedule reminders for updates (30-day deadline for changes).

PART 4 – CHANGE MONITORING TEMPLATE

Track changes in ownership, control, address, or identifying information. Use this log to ensure updated filings within 30 days of reportable changes.

[// GUIDANCE: Maintain client data in compliance with privacy and data security requirements.]