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@Jim-from-Ohio wrote:

So far I have filed maybe a dozen or two BOI reports.. even filed one for a client that does not have a U.S drivers license but they have a passport.. Generally going smoothly.  Good side business filing these. 

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Interesting.  I think the rule is if the document number changes you have to file an updated report.  In VA when you renew your license you keep the same document number (but just get a new issue/exp date) so that would NOT require a BOI update.  But passports are issued with a new number so when the passport is renewed it would have to be uploaded again.  Interesting question though, what if the passport is never renewed?  When it expires I assume there would be a requirement to upload an image of a different valid document instead.

Practically, who's going to keep track of all that?  There's no way (yet?) to retrieve a filed report so unless the filer made a copy of it at the time of filing there's no way to even know what was submitted (and even if it was printed/saved, of course, all of our clients keep these critically important documents forever, right?)

I personally don't see the initial filing as a big deal, I think the big deal is failure to update timely.  Heck, half the time I don't find out that my clients moved until the following year.  A lot of them don't bother changing their driver's license or vehicle registration until something expires.  But FinCEN expects them to do this BOI update in 30 days?