BOI Reporting Update: What Clients Still Ask and How Firms Can Respond

If your client base includes small businesses, real estate investors, or anyone who formed an LLC in the last few years, you have probably lived through the same cycle: a wave of “Do I have to file BOI?” messages, followed by a wave of “I heard it got blocked,” and then another wave of “Wait, is it back?”

Here is the cleanest way to frame the update as of today: FinCEN’s interim final rule narrowed BOI reporting so that entities created in the United States are no longer required to file BOI reports. BOI reporting is now aimed at certain foreign entities registered to do business in the U.S., and even then, U.S. persons generally do not have to be reported as beneficial owners. You can verify the current posture directly on FinCEN’s official pages: the main BOI Reporting page, the Interim Final Rule Q&A, and the BOI FAQs.

This shift is why client questions have not stopped. The rules changed, but the headlines, third-party checklists, and bank KYC requests often lag behind.

The short version you can tell most U.S. formed entities

For a typical domestic LLC or corporation formed by filing with a state, the response can be concise:

• U.S. created entities are not required to file BOI under the current FinCEN interim final rule.
• If they already filed earlier, FinCEN’s Q&A states domestic entities are exempt from filing initial reports and also from updating or correcting previously filed BOI reports.

That alone resolves the majority of inbound questions.

Who still needs BOI triage

The remaining complexity is usually not “What is BOI?” It is “Does this apply to my specific structure?”

Under the interim final rule, the focus is on foreign entities that register to do business in any U.S. state or tribal jurisdiction and that do not qualify for an exemption. FinCEN’s overview and deadlines are summarized here: Beneficial Ownership Information Reporting.

A practical way to spot likely BOI candidates in your client list:

• Entities formed under non-U.S. law that filed to do business in a U.S. jurisdiction (often visible in entity records as a “foreign” registration).
• Cross-border groups that hold U.S. operating entities, even if the U.S. entity itself is domestic and now exempt.
• Clients with an overseas parent who registered the parent directly to do business in the U.S. rather than forming a U.S. subsidiary.

If the entity truly is a foreign reporting company, your team can route them to FinCEN’s filing system: the BOI E-Filing

What clients still ask (and response language you can reuse)

“So BOI is cancelled, right?”

A better answer than yes/no is:
BOI requirements were narrowed. Domestic U.S. created entities are exempt under the current interim final rule, but some foreign entities registered to do business in the U.S. still have obligations. Point them to FinCEN’s BOI page for the official scope statement.

“I formed an LLC in 2024 and did not file. Am I in trouble?”

For a U.S. formed LLC:
Under the current rule, that domestic entity is exempt, and FinCEN has stated domestic entities do not need to file BOI.

“We already filed. Do we need to update if ownership changes?”

For a U.S. formed entity:
FinCEN’s interim final rule Q&A indicates domestic entities are exempt from updating or correcting previously filed BOI reports.

For a foreign reporting company:
Direct them to the official instructions and FAQs, because the duty to update can still apply to covered reporting companies.

“My bank is asking for BOI. What do I do?”

This is increasingly common. Banks and vendors run their own customer due diligence. Even if a domestic entity is exempt from BOI filing, a bank can still request ownership details for KYC.

Your response can be:
“We can help you gather the ownership details your bank is requesting, but that is separate from a federal BOI filing obligation. BOI filing requirements are explained here: FinCEN BOI.”

This is where firms can turn a reactive scramble into a standardized, billable workflow.

How firms can respond without burning partner time

Even when the correct answer is “you are exempt,” the work is not zero. Someone must:

• Read and interpret the structure
• Reply consistently
• Document the rationale
• Track foreign registrations
• Handle bank KYC questionnaires that look like BOI

That is operational work that competes with tax season.

This is exactly the kind of workload that benefits from a seat-based support model: a dedicated resource who works inside your tools, follows your templates, and keeps the partner out of the weeds.

At Finsmart, we often see firms split BOI-related workload into two lanes:

• Client communications and triage (identify whether it is domestic exempt vs foreign registered, gather basic facts, draft the response, maintain a tracker)
• Technical review (final check of the message, confirm the determination, ensure consistent positioning across the firm)

That maps naturally to a combination of an execution seat plus a reviewer layer. As one firm owner put it, “One of the things my internal team has appreciated is that the Finsmart team has always felt like a part of our team. They’re included in our meetings, collaborate seamlessly, and bring efficiency and productivity that we truly value.”

And even though BOI is not tax prep, it shows up during tax prep. When your senior team is reviewing returns and client deliverables, the last thing you want is compliance noise pulling them away from production. This is where a blended model can help: keep returns moving with a dedicated USA Tax Seat and handle compliance communications through your Accounting Seat Model, so partners stay focused on high-value conversations.

If your immediate constraint is volume rather than staffing, we also support pay-per-return (in batches of 50) for U.S. tax preparation, which can free up internal reviewers to handle the BOI and KYC questions that still hit your inbox.

A related client sentiment we hear often is about freeing the firm from transactional drag: “I use Finsmart to outsource the transactional side of my client’s business. I am loving the service, and I’m recommending it to everyone.” 

A simple “BOI clarity” message you can send clients

If you want a quick outbound note that reduces inbound tickets, it can be as short as:

• “FinCEN has revised BOI reporting so U.S. created entities are currently exempt.”
• “Foreign entities registered to do business in the U.S. may still have filing obligations.”
• “If you have a foreign entity or are unsure, reply with the entity name and formation jurisdiction and we will confirm the category.”

If you want, I will tailor this to your firm’s book of business

If you share your rough mix of clients with foreign registrations (how many, which states, common ownership patterns), I can draft a firm-branded client email, an internal triage checklist, and a tracker layout that a dedicated seat can run inside your workflow. Send it to [email protected] and I will tailor the response pack to your reality, including where a USA Tax Seat or reviewer coverage fits best during busy season.