Loan impact
From the comments text · verifiedApplies to: Applies to entities subject to FinCEN beneficial ownership information reporting under the Corporate Transparency Act, not to specific mortgage loans.
- Effective
- Mar 26, 2025
- Applicability confidence
- Verified: every row above is supported by the source text
What changed
From the comments text · Sections 31 CFR 1010.380(c), 31 CFR 1010.380(a)(1), 31 CFR 1010.380(d)(4), 31 CFR 1010.380(b)(2)(iii)| Requirement | Previously | Now |
|---|---|---|
| Domestic reporting companies exempted from BOI reportingRelaxedSection 31 CFR 1010.380(c) | Previously: Reporting companies, including domestic ones, were required to comply with BOI reporting by January 1, 2025 under existing regulations. | Domestic reporting companies need not report BOI or update or correct previously reported BOI. |
| Foreign reporting company BOI filing deadline extendedRelaxedSection 31 CFR 1010.380(a)(1) | Previously: Reporting companies were required to comply with BOI reporting by January 1, 2025 under existing regulations. | Entities that became reporting companies before March 26, 2025 must file by April 25, 2025; later entities file within 30 days of registration notice. |
| U.S. person beneficial owners exempted from BOI reportingRelaxedSection 31 CFR 1010.380(d)(4) | Not stated | Reporting companies need not report BOI of U.S. persons who are beneficial owners; U.S. persons need not provide it. |
| Foreign pooled investment vehicle special rule revisedRelaxedSection 31 CFR 1010.380(b)(2)(iii) | Previously: Foreign pooled investment vehicles were required to report BOI solely with respect to an individual who exercises substantial control over the entity. | Foreign pooled investment vehicles report only an individual with substantial control who is not a U.S. person. |
What to do
AWACS interpretation · not source languageWhat to review: No change is mandatory, so first review whether the lender is itself a reporting company under FinCEN's BOI rule. If it is, note that the rule, effective March 26, 2025, lets domestic reporting companies skip BOI reporting and lets reports leave out U.S. persons' BOI. It also sets an April 25, 2025 deadline for foreign reporting companies that existed before March 26, 2025, and the record does not tie any of this to specific mortgage loans.
QC implications
- No change in this record is mandatory for lenders, so there is no new required control to test.
- If the lender handles FinCEN beneficial ownership information reporting under the Corporate Transparency Act, QC may check that its records match the relaxed scope: domestic reporting companies are exempt, and U.S. persons' BOI is exempt from reports.
- QC may check that any foreign reporting company in scope is not treated as exempt, and that its record shows the April 25, 2025 filing date for entities that became reporting companies before March 26, 2025.
Source and record
Version 1 · archivedChecks passed
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- Loan impact vocabulary
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- Audience verbatim
- Scope residential
- Out of scope
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Source
- Interim final rule; request for comments FR Doc. 2025-05199 (official) ↗ (opens in a new tab)
- Archived copy, SHA-256 bb2fc2ee54b8…
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