Are third-party service providers required to maintain records validating that they are authorized to file on behalf of a reporting company?

FinCEN does not require third-party service providers to maintain any specific record validating that they are authorized to file on behalf of a reporting company. A third-party filer who willfully files a false or fraudulent beneficial ownership information (BOI) report with FinCEN, however, may be subject to civil and criminal penalties. As a best practice, a third-party filer thus may want to consider maintaining documentary records relevant to BOI reports filed on behalf of reporting companies.