March 23, 2025

Team GRC has just spotted some very good news for NPA members: FinCEN is removing the Beneficial Ownership Information Reporting regulation (“BOIR”) for all U.S. Companies and All U.S. Persons. All U.S. Companies and U.S. Persons are now exempt from the BOIR regulation, as soon as the interim final rule issued on Friday, March 21, 2025, appears in the Federal Register. The text of the interim final rule is available at https://fincen.gov/resources/statutes-regulations/federal-register-notices/beneficial-ownership-information-3 but we cannot predict when it will appear in the Federal Register. Occasionally, the text that is published in the Federal Register will vary slightly from the agency’s own text.

Based on our first take on the interim final rule, any foreign entity that meet the newly revised definition of “reporting company” will not be required to report any U.S. persons as “beneficial owners.” U.S. persons will not be required to report BOI with respect to any foreign entity for they are a beneficial owner.

For NPA members, pawnbrokers and vendor members alike, this is very good news. Team GRC will keep our eyes on any additional developments regarding BOIR.

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