FinCEN estimates millions of hours will be spent seeking BOI access
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Entities seeking access to beneficial ownership information (BOI) will spend over 8.7 million hours filling out paperwork in the first year and over 3.6 million in the second year, the Financial Crimes Enforcement Network (FinCEN) said in an estimate Monday.

FinCEN posted the estimate in the Federal Register as part of a 30-day notice seeking comment on the information to be collected from certain authorized recipients requesting access to BOI. Comments are due by Aug. 22.

FinCEN estimates that nearly 16,000 entities will seek BOI access, with most — 15,716 of 15,934 — being financial institutions. The others are state, local, and tribal law enforcement agencies; state regulatory agencies; and self-regulatory organizations (SROs). SROs cannot make BOI requests to FinCEN but can receive BOI via redisclosure from other entities in some circumstances

The notice gives the public an opportunity to comment on the information to be collected from certain persons requesting BOI from FinCEN and on FinCEN’s estimate of the burden involved in the information collection.

This notice follows a 60-day notice on BOI requests that FinCEN previously issued for public comment on the Beneficial Ownership Information Access and Safeguards Rule.

The Corporate Transparency Act (CTA), P.L. 116-283, authorized government agencies, financial institutions, and their regulators to obtain BOI under certain specified circumstances for national security and law enforcement purposes.

Under the CTA, which Congress passed in 2021 as an anti-money-laundering initiative, reporting companies must disclose the identity and information about beneficial owners of the entities. For new entities incorporated after Jan. 1, 2024, reporting companies must also disclose the identity of “applicants” — defined as any individual who files an application to form a corporation, limited liability company, or other similar entity.