Looking for BOI Reporting engagement letter templates with FinCEN - any recommendations?

Do you also include language about the client being responsible for determining who qualifies as a beneficial owner? That's been a gray area for some of my clients who aren't sure if certain stakeholders meet the substantial control test.

Absolutely - that's a critical component. I explicitly state that the client is solely responsible for identifying all beneficial owners according to FinCEN's criteria. I also include that they need to determine who meets either the 25% ownership threshold or the substantial control test. I've found it helpful to attach FinCEN's own guidance document as an exhibit to the engagement letter so they can't claim they didn't understand the requirements. This has been particularly useful with clients who have complex ownership structures or family trusts involved.

Does it handle complex ownership structures like multi-tier entities where you have companies owning other companies? That's where I'm getting stuck - trying to determine how far up the chain we need to go with our reporting.

I've been debating using a specialized tool. How does it handle the security aspect? I'm concerned about storing all that sensitive beneficial owner information (SSNs, home addresses, etc.) in yet another system.

It definitely handles multi-tier entity structures - that's actually where it's most valuable. The system visually maps out ownership chains and identifies which individuals need to be reported at each level, even when there are multiple layers of entities involved. As for security, that was my biggest concern too. They use bank-level encryption and don't actually store the SSNs permanently - they're encrypted during the filing process and then purged from their system. You can also enable two-factor authentication for accessing client data. I was initially skeptical but their security documentation convinced me it's safer than keeping these records in my own systems.

How exactly does this service work? Do they just stay on hold for you or something? I've been trying to get clarification from FinCEN about whether we need separate engagement letters for initial filings versus annual updates.

Sounds sketchy. I've heard these "skip the line" services just tie up more phone lines making the problem worse for everyone. Did they actually provide anything you couldn't get from the FinCEN website FAQs?

They use call technology that secures your place in line but doesn't keep a phone line open. When you're near the front of the queue, they call you and connect you directly to the next available agent. You're not paying to "cut" in line, just to not personally wait on hold. Yes, they provided specific guidance that wasn't on the FAQ. For example, they clarified that if you're listed as the company applicant, you need explicit language in your engagement letter stating you have no ongoing monitoring responsibility unless specifically engaged for annual updates. The agent walked through exactly what needs to be in an engagement letter from their perspective, which was incredibly valuable.

I don't see any attachment? Could you repost or share how you're handling the documentation retention section specifically? We're debating whether we need to keep the verification documents (IDs, etc.) or just the information.

Sorry about that! Can't believe I forgot to attach it. For document retention, we specify that we keep the FinCEN filing confirmation and basic ownership information for 7 years per our normal tax record retention policy. We explicitly state that we do NOT retain copies of government IDs, birth certificates or other verification documents provided by beneficial owners. We view these documents only to verify the information being filed and then either return or destroy them. This reduces our liability for storing sensitive personal documents while still fulfilling our professional obligations.

We've found a tiered flat fee structure works best. Basic fee for entities with 1-3 beneficial owners, then an additional fee per owner beyond that. We also charge separately for amendments and updates. This has been easier to explain to clients than hourly billing, and honestly more profitable since we've gotten efficient at the filings.