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The Corporate Transparency Act: Compliance and Reporting Deadlines

09 January 2024

Part 2 of a series –

In case you missed it, the previous part of this series provided an introduction to the Corporate Transparency Act (the “CTA”) and two of its defined terms, the Reporting Company and Beneficial Owner.  See our CTA Part 1 article to find out more about who is considered a Beneficial Owner and what types of businesses are considered Reporting Companies. (Spoiler: most businesses.)

We now turn to the reporting required by the US Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).

Reporting Deadlines

Compliance deadlines for Reporting Companies are dependent upon when the entity was created.

  • Reporting Companies created before January 1, 2024 have until January 1, 2025 to file their Beneficial Ownership Information Report (“BOIR”).
  • Reporting Companies created on or after January 1, 2024 have 90 days to file their initial BOIR. Commencing on January 1, 2025, the 90-day timeframe will be shortened to 30 days.

The Beneficial Ownership Information Report (“BOIR”)

The BOIR must contain the Reporting Company’s legal name, current address, state of formation and taxpayer identification number (or equivalent). Further, the BOIR must include each Beneficial Owner’s name, date of birth, residential address and a photo of acceptable identification.

For a Reporting Company created on or after January 1, 2024, there is an additional requirement. The company applicant (the individual who files the document that creates the domestic company) must disclose similar information.

If there is any change to the information submitted to FinCEN regarding the Reporting Company or its Beneficial Owners, these changes must be reported within 30 days. Further, if you become aware that any information in a BOIR is inaccurate, it must be corrected within 30 days. The form BOIR is now available on the FinCEN website at https://www.fincen.gov/boi.

To learn more about CTA compliance, contact us via email or call our offices at 469.916.7700.