Securities Regulation Daily Wrap Up, BENEFICIAL OWNERSHIP—Treasury’s OIG summarizes beneficial ownership information comments and complaints, (Jun 10, 2026)

By Sherri M. Schroeder, J.D.

The report separated the comments and complaints into 10 categories and then summarized the 94 comments, complaints, and responses received or made between Dec. 14, 2021, and Dec. 31, 2025.

In a letter addressed to the Chairmen and Ranking Members of the U.S. Senate and House of Representatives, the Treasury’s Office of Inspector General (OIG) fulfilled part of its required duties under Section 6403 of the Corporate Transparency Act (CTA) by submitting a report summarizing the external comments or complaints and related investigations conducted by OIG related to the collection of beneficial ownership information (BOI). Although the report did not include the required recommendations to improve the form and manner of notification, collection, and updating processes of the BOI reporting requirements, the report did summarize the comments and complaints received by the OIG from Dec. 14, 2021, to Dec. 31, 2025. After further analyzation, which included reviewing the rulemakings of the Financial Crimes Enforcement Network (FinCEN), guidance such as FAQs and web resources, and actions taken by FinCEN to address the issues raised, OIG categorized the 94 comments and complaints related to the CTA and BOI reporting and separated them into 10 categories, as discussed below.

Requirement. Section 6403 of the CTA requires Treasury’s OIG to provide public contact information to receive external comments or complaints regarding the BOI notification and collection process or regarding the accuracy, completeness, or timeliness of such information. In December 2021, OIG created a dedicated email address— CorporateTransparency@oig.treas.gov—for that purpose. The OIG received its first complaint on Sept. 26, 2023.

During the period of Dec. 14, 2021, to Dec. 31, 2025, OIG received more than 20,000 emails and determined that 84 of them related to the CTA and BOI reporting, comprising 94 comments and complaints. OIG then categorized them as follows: (1) Fraudulent Solicitation; (2) Reporting Requirements; (3) FinCEN Web Resources; (4) FinCEN Contact Center; (5) Notification and Outreach; (6) Exemptions; (7) Objections to Reporting; (8) Third-Party Service Providers; (9) Removal of BOI; and (10) Access to Data.

Fraudulent Solicitation. Twenty-five comments related to alleged potential fraudulent attempts to solicit information or money from individuals or entities subject to BOI reporting requirements. Of these, 13 appeared to be fraudulent attempts to solicit information or payment from filers, four appeared to be advertisements for legitimate services, and eight did not contain enough information to indicate whether the attempted solicitation was fraudulent. OIG stated it was investigating and coordinating with FinCEN, which was already aware of the attempts and posted an alert on its BOI website.

Reporting Requirements. Fifteen comments or concerns related to BOI reporting requirements were received. These included general complaints about the process, difficulties in understanding how to file, and confusion about deadlines and who must report.

FinCEN Web Resources. Ten complaints were made related to difficulties accessing FinCEN websites and BOI web forms. Of these, six related to errors received when applying for an ID or filing a BOI report, two related to issues accessing FinCEN’s website, and two related to improper confirmation messages.

FinCEN Contact Center. Nine comments and complaints were received related to FinCEN’s Beneficial Ownership Contact Center (BOCC). These included six related to the BOCC’s failure to provide an adequate response and one each related to lack of assistance with BOI inquiries through FinCEN’s Regulatory Helpline, a request to the BOCC for assistance filing a BOI report, and one related to the way inquiries are submitted through FinCEN’s Regulatory Helpline.

Notification and Outreach. Eight comments and complaints related to concerns about a perceived lack of notification from FinCEN to the public about BOI requirements. Of these, seven related to public awareness of the reporting requirements, and one related to the public’s knowledge of their ability to contact OIG with their complaints and comments.

Exemptions. Eight comments related to existing statutory exemptions from BOI reporting requirements or requests for additional exemptions were received. These included five that wanted to add certain non-political organizations, such as homeowners associations, to the CTA’s list of exempt entities, and three others relating to the definition of public utilities, qualification of pooled investment vehicles, and guidance for large operating companies.

Objections to Reporting. Seven comments and complaints about general objections to BOI reporting requirements were received. Of the four that included additional details, two complained the government already had enough tools to collect BOI and track down financial-sector crimes, and two complained the collection of BOI violates the Fourth Amendment and the Eighth Amendment to the U.S. Constitution.

Third-Party Service Providers. Six comments related to third-party service providers, such as accountants or lawyers, who provide BOI reporting services for beneficial owners. Of these, three were concerned that accountants or financial advisors could be construed as practicing law without authorization if they assisted with BOI filings, two were concerned about their third-party providers’ ability to access tools to facilitate BOI reportings, and one related to reporting third-part providers’ personal information as a company applicant.

Removal of BOI. Four complaints were received that related to the removal of BOI data from FinCEN’s database for domestic reporting companies that have submitted reports.

Access to Data. Two comments were received concerning data access. One wanted to know who would be able to access information collected under the CTA, and one inquired as to the CTA’s and FinCEN’s safeguards to prevent the solicitation of financial services to individuals who report BOI.

FinCEN’s response. In its response, FinCEN first noted that the report did not include the recommendations required by the CTA to be made in coordination with FinCEN to improve BOI reporting. The agency then noted, “As the Draft Report notes, on March 26, 2025, Treasury issued an interim final rule (IFR) that removed the requirements for U.S. companies and U.S. persons to report BOI under the CTA. The comment period for this IFR closed on May 27, 2025, and Treasury continues to work diligently to finalize the rule.”

RegulatoryActivity: BeneficialOwnership FormsFilings