In a recent letter to the Department of the Treasury and the Financial Crimes Enforcement Network (FinCEN), the American Institute of CPAs (AICPA), together with 54 state CPA societies, expressed serious concerns with the rollout and push to implement FinCEN’s Beneficial Ownership Information reporting requirement without regard for the impact to the small business community.

The AICPA has submitted past letters to FinCEN and the U.S. Congress noting concerns about the constricted timeline for the small business community to understand the reporting requirement and urging caution regarding the failure to provide a reasonable timeframe for small businesses to comply with BOI for both new and existing entities. Additionally, the AICPA has raised concerns over the estimated burden hours and associated time-cost which has effectively become a 30-day tracking requirement.

The AICPA and state CPA societies are urging FinCEN to suspend all enforcement actions until one year after the conclusion of all court cases related to NSBA v. Yellen and take no retroactive enforcement actions for non-compliance during this time period.