THE FREQUENT FILER

With the new Beneficial Ownership Information Reporting (BOIR) requirements outlined by the Corporate Transparency Act (CTA), it is to be expected that different states would have their own requirements, in addition to the CTA requirements. Below, we discuss which states have which requirements, and how FinCEN Filing Agents can help you remain compliant.  

California 

Senate Bill 1201 requires domestic and foreign corporations and LLCs to include the names and complete business or residence addresses of any beneficial owner in their annual statement of information. Domestic and foreign LLCs are also required to file a real estate investment trust to the Secretary of State, which is a statement containing the name and complete business or residence address of any beneficial owner. The bill was passed in the Senate May 23, 2024 but the Assembly did not pass and it is not yet signed into law.  

District of Columbia 

Since January 1, 2020, the District has required beneficial ownership information from all entities who are formed or registered to do business in the District.  Sections 29–102.01 and 29–102.11 of the DC Code require the formation and registration filings of all domestic and foreign entities, as well as their biennial reports, include the name, residence, and business address of each person who holds shares of direct or indirect, legal, or beneficial ownership. These shares must exceed ten percent, or not exceed ten percent, provided that the person controls the financial or operational decisions of such entity or has the ability to direct the day-to-day operations of such entity. 

Maryland 

Senate Bill 954 would require each reporting entity to file a document containing information about each beneficial owner and applicant with the State Department of Assessments and Taxation. An amended report would be required upon a change in the reported information. Hearings were held in February 2024, but the Senate has yet to vote on the proposed legislation. 

Massachusetts 

House Bill 3566 would require all domestic LLCs to disclose information about each beneficial owner in their certificate of organization and all foreign LLCs to disclose information about their beneficial owners in their application for registration. Amendments must be filed upon a change in beneficial owners or their disclosed information. A study was ordered by the committee in May of 2024. The bill has yet to be voted on. 

New York 

On March 1, 2024, New York’s Governor Hochul signed Senate Bill 8059 requiring all LLCs formed under New York law (domestic LLCs) or formed elsewhere and registered to do business in New York (foreign LLCs) to file either a beneficial ownership disclosure or an attestation of exemption with the New York Department of State. 

How can FinCEN Filing Agents help? 

FinCEN Filing Agents is your BOIR filing solution. FinCEN Filing Agents offers an efficient and effective BOIR filing solution that pays attention to compliance on a federal and state level, offering you a seamless experience with BOIR filing. Partner with FinCEN Filing Agents and file your Beneficial Ownership Information with confidence! 

Learn more here: FinCEN Filing Agents Beneficial Ownership Information Reporting  

About Us


The company behind FinCEN Filing Agents, EdgarAgents, has been in business since 2008. We are a leading regulatory compliance filing agency having filed nearly 500,000 reports to SEC, FinCEN, and other entities since its inception. EA serves registered asset management companies, public and private companies, beneficial owners, their in-house and outside counsel, corporate compliance teams, advisory and accounting teams, private equity, and investment banking partners.

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CORPORATE TRANSPARENCY ACT - BOIR