Businesses across the United States have until January 1, 2025 to file their initial beneficial ownership information
(BOI) reports. BOI reports should be filed through FinCEN’s website at https://www.fincen.gov/boi.

Exemptions
Dealers have questioned if they are exempt from filing these BOI reports. Twenty-three types of entities are exempt from the beneficial ownership information reporting requirements. These entities include publicly traded companies meeting specified requirements, many nonprofits, and certain large operating companies.

Two of the exemptions may apply to dealers and their related entities.
1. Being a large operating company; and
2. Being a subsidiary of an exempt entity (such as a large operating company).

To use the “large operating company” exemption, the entity must meet six factors, which include having 20 fulltime
employees that are employed in the United States; having a physical presence in the United States, and having filed a federal tax return for the previous year demonstrating at least $5,000,000.00 in gross receipts or sales.

To use the subsidiary exemption, the entity need only be controlled or wholly owned, directly or indirectly, by another exempt entity.

To further review exemptions and for a list of frequently asked questions, visit: https://www.fincen.gov/boi-faqs.

FinCEN expects that many, if not most, businesses will be able to submit their beneficial ownership information to FinCEN on their own using the guidance FinCEN has issued. Extreme penalties could be faced for noncompliance.

Complete BOI reports through FinCEN’s website before January 1, 2025 at: https://www.fincen.gov/boi.