What are the key changes between the interim final rule (IFR) and the final rule?

The final rule adopts all of the changes made on an interim basis by the IFR as permanent changes to the beneficial ownership information (BOI) reporting requirements. Most notably, the final rule permanently removes the requirement for U.S. companies and U.S. persons to report BOI to FinCEN. In addition, the final rule makes two substantive changes that expand on the relief the IFR extended relating to U.S. persons. • It exempts foreign companies from the requirement to report U.S. person “company applicants” (i.e., the individuals who helped those foreign companies register to do business in the United States). • It exempts U.S. persons who have applied for FinCEN identifiers (FinCEN IDs) from having to update or correct the information they provided to FinCEN when they applied.