Federal Beneficial Ownership Reporting Requirements

By Brett Richardson, RVDA Director of Legal & Regulatory Affairs

Federal "Beneficial Ownership Information" (BOI) Reporting Requirements went into effect earlier this year. This mandate, stemming from the Federal Corporate Transparency Act (CTA) enacted in 2021, introduces a new layer of transparency aimed at enhancing the integrity of the U.S. financial system.

Its primary goal is to prevent the misuse of anonymous entities for money laundering and concealing assets by requiring detailed reporting of the beneficial owners of various business entities.

RVDA worked with the National Federation of Independent Businesses and nearly 100 national trade associations on a campaign to lessen the impact of the CTA on small businesses.  Congress may consider legislation to delay implementation of this rule, but to prepare, here is some information to get ready to comply with the rule if it stands as issued.

Key Dates and Requirements:

  • Entities Formed or Registered Before January 1, 2024: You are required to submit your initial BOI reports by January 1, 2025.
  • Entities Created Between January 1, 2024, and December 31, 2024: You must file your BOI within 90 days of your formation date.
  • For Entities Formed After January 1, 2025: Reporting must be completed within 30 days.

Who Needs to Report: This requirement applies to many corporations, limited liability companies (LLCs), and other entities, both U.S.-based and foreign, that are created in or registered to conduct business in the United States.

How to Report and Resources for Compliance: All BOI reports must be submitted electronically via the Financial Crimes Enforcement Network (FinCEN) website. To file your report, visit: www.fincen.gov/boi

Access to Information: The submitted information will be securely stored and made accessible to federal, state, and local law enforcement agencies, foreign governments, and financial institutions under strict conditions. In many cases, formal requests or court orders will be necessary to access the data.

The application of these requirements to RV vehicle dealers specifically can depend on various factors, including the legal structure of the dealership (e.g., incorporated as an LLC or another entity type that falls under the CTA's purview) and any exemptions that may apply.

Given the complexity of these laws and the potential for updates or changes in guidance, it is advisable for businesses to consult with legal professionals who specialize in corporate law, financial regulations, or compliance. Such professionals can provide tailored advice based on the latest regulations and the specific circumstances of the dealership.


FinCEN has learned of fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act. These fraudulent scams may include:

  • Correspondence requesting payment. There is NO fee to file BOI directly with FinCEN. FinCEN does NOT send correspondence requesting payment to file BOI. Do not send money in response to any mailing that claims to be from FinCEN or another government agency.

  • Correspondence that asks the recipient to click on a URL or to scan a QR code. Those e-mails or letters are fraudulent. Do not click any suspicious links or attachments or scan any QR codes in emails, on websites, or in any unsolicited mailings.

  • Correspondence that references a “Form 4022,” or an “Important Compliance Notice.” This correspondence is fraudulent. FinCEN does not have a “Form 4022.” Do not send BOI to anyone by completing these forms.

  • Correspondence or other documents referencing a “US Business Regulations Dept.” This correspondence is fraudulent; there is no government entity by this name.