Addressing Concerns with FinCEN's New Reporting Rules

The Financial Crimes Enforcement Network ("FinCEN") recently waded into unexpected controversy with the release of proposed data fields for the beneficial ownership information ("BOI") reporting regime that will take effect at the beginning of next year. FinCEN's inclusion of "Unknown" and "Unable to identify" options for several of the proposed data fields has generated concern that incomplete BOI may be less valuable for some users, such as financial institutions. These concerns stand in contrast to the potential impossibilities and practical constraints that reporters of BOI face. Please join Mayer Brown partners Brad Resnikoff and Matt Bisanz as they discuss this controversy and how it may affect the implementation of the BOI reporting regime.