If you own a limited liability company (LLC) or small business in Michigan, you’ve probably heard about the Corporate Transparency Act (CTA) and its new reporting rules. The law requires companies to report beneficial ownership information (BOI) to the federal government. But as of March 2025, there have been some major changes that affect those who might actually need to file the report for compliance.
- Understanding BOI Reporting under the Corporate Transparency Act
- Does Your LLC Qualify—or Qualify for Exemption?
- What BOI You Must Disclose to FinCEN
- Filing Mechanics, Deadlines, and Update Obligations
- Secure BOI Compliance with Bowen Hoogstra Law
Here’s the good news—many domestic companies are now exempt from the reporting obligation. So what does that mean for you? Does your company still need to submit the required report, or has your business been taken off the hook? Let our competent Muskegon lawyer break down the latest updates on BOI reporting under the Corporate Transparency Act for your guidance.
Understanding BOI Reporting under the Corporate Transparency Act
The Corporate Transparency Act (CTA) officially took effect on January 1, 2024, as part of the federal government’s efforts to combat money laundering, terrorist financing, and other forms of financial crime. The law requires certain types of U.S. and foreign companies to report information about their “beneficial owners,” the individuals who own or control the company, to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury. That obligation is known as beneficial ownership information (BOI) reporting.
Failure to comply with the BOI reporting requirement can lead to serious consequences. We’re talking about civil penalties that can reach up to $591 per day for each day of non-compliance, and in more severe cases, even criminal penalties, including fines and imprisonment for up to two years. That’s why it’s important to understand your obligations and take them seriously. If you’re unsure about your reporting duties, seeking guidance from an experienced Muskegon lawyer specializing in business law can be invaluable to ensure you remain compliant and protect your business.
Does Your LLC Qualify—or Qualify for Exemption?
On March 26, 2025, FinCEN released a significant update to its BOI reporting rules. Under the interim final rule, the definition of a “reporting company” was revised to apply only to foreign entities—that is, entities formed under the laws of another country that have registered to do business in a U.S. state or tribal jurisdiction. That means domestic reporting companies, including many LLCs formed under Michigan law, are no longer required to file BOI reports.
The rule change represents a huge shift in BOI compliance. If your Michigan-based LLC was previously considered a domestic reporting company, it might now be fully exempt from filing requirements under the updated interpretation of the CTA. But even with the exemption for domestic companies, the CTA still includes other types of entities that are exempt from reporting requirements, regardless of whether domestic or foreign. These are:
- Accounting Firms
- Banks
- Brokers or Dealers in Securities
- Commodity Exchange Act Registered Entities
- Credit Unions
- Depository Institution Holding Companies
- Financial Market Utilities
- Governmental Authorities
- Insurance Companies
- Investment Companies or Investment Advisers
- Large Operating Companies
- Other Exchange Act Registered Entities
- Public Utilities
- Securities Exchange or Clearing Agencies
- Securities Reporting Issuers
- State-Licensed Insurance Producers
- Tax-Exempt Entities
- Venture Capital Fund Advisers
These exemptions are designed to avoid duplicating regulatory oversight and to ease the burden on companies that already report similar ownership information to other agencies. Still, many small LLCs and startups in Michigan might not meet the exemption criteria. It’s best to review the current structure of your company with a local Muskegon lawyer to make sure you’re not overlooking a filing obligation or wrongly assuming you’re exempt.
What BOI You Must Disclose to FinCEN
Even with the recent changes, if your business falls under the new, narrower definition of a “reporting company,” meaning it’s a foreign entity registered to do business in the U.S. that doesn’t qualify for one of the specific exemptions, you still have important disclosure obligations to FinCEN. The report requires details about your company and the individuals who have significant control or ownership.
For the company itself, the BOI report must include:
-
- Legal name of the business
- Any trade names or “doing business as” (DBA) names
- Taxpayer Identification Number (TIN) or a foreign tax identification
- The physical address of your principal place of business in the U.S.
- The state or jurisdiction where the company was formed or registered
- The type of report—an initial report, a correction to a previous report, or an update
For each beneficial owner, the reporting company must provide:
-
- Full legal name
- Date of birth
- Residential address
- A government-issued ID number
- The state or country that issued the ID
- A scanned image of the ID document
It’s essential to be accurate with all the information required. Any errors or omissions could lead to delays or, worse, compliance issues.
Filing Mechanics, Deadlines, and Update Obligations
Filing of the BOI report is done online through the FinCEN BOI E-Filing system. The system is designed to be user-friendly, allowing you to either fill out a web-based version of the BOI report directly or upload a finalized PDF version of the BOI report. Gather all the necessary documents and details beforehand to streamline the filing process.
Make sure all required fields are completed and that you attach images of the identification documents for each beneficial owner. FinCEN does not charge a fee for direct BOI filings, so be wary of any solicitations demanding payment to file. The deadline for your initial BOI report depends on when your company was created or registered to do business in the U.S.
Remember, filing your initial report isn’t the end of your obligations. The CTA requires you to keep your BOI up to date. If there is any change to the required information about your company or its beneficial owners in the BOI report filed, your company must file an updated report. The updated report needs to be filed no later than 30 days after the date the change occurred.
Secure BOI Compliance with Bowen Hoogstra Law
While the recent FinCEN interim final rule has reduced the burden for many domestic Michigan LLCs, if your company is a foreign entity registered to do business in the U.S., you still have BOI reporting obligations under the Corporate Transparency Act. Bowen Hoogstra Law is here to ensure your business remains compliant in 2025 and beyond.
We offer a flat-fee BOI audit and filing service tailored specifically for Michigan business owners. Our qualified Muskegon attorneys can simplify the process for you, ensuring accuracy and timely submission so you don’t have to worry about missing deadlines or facing unexpected penalties. Contact us today at (231) 726-4484 or here for a consultation.