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Our attorneys stay on top of changes in legislation, agency regulations, case law, and industry trends—then craft timely legal alerts to keep clients up to date on legal developments important to their business.

September 23, 2024

Beneficial Ownership Reporting Requirements Under the CTA: Third-Quarter Reminder

The deadline by which entities formed prior to January 1, 2024, must comply with the Corporate Transparency Act (CTA) is fast approaching!

As noted in our previous alerts, the CTA, which became effective January 1, 2024, requires entities formed before January 1, 2024, to file their initial beneficial ownership interest (BOI) report by December 31, 2024. It also requires entities formed after January 1, 2024, and before January 1, 2025, to file their initial BOI report within 90 calendar days after formation (those formed after December 31, 2024, will have 30 days after formation), unless an exemption applies.

The CTA requires corporations, limited liability companies (LLCs), limited partnerships, and other qualifying entities (reporting companies) to disclose and maintain up-to-date identifying information with the Financial Crimes Enforcement Network (FinCEN) by filing BOI reports and amendments, which include:

  • The entity’s legal name
  • Any trade names
  • Principal place of business
  • Jurisdiction(s) of registration
  • The Taxpayer Identification Number (TIN) affiliated with the entity
  • Identifying details of individuals who directly or indirectly own or control the reporting company

FinCEN has reported lower-than-expected activity and a surge in public comments looking for additional guidance. Despite the lack of guidance on many issues, the deadline to file BOI reports is unlikely to be extended. Therefore, clients should plan on December 31, 2024, being a hard deadline for entities formed before January 1, 2024, to file their BOI reports. Barclay Damon’s Corporate Practice Area can assist in determining filing obligations as well as submission of the required filings. 

If you have any questions regarding the content of this alert, please contact Jim Canfield or Mike Moore, Corporate Practice Area co-chairs, at jcanfield@barclaydamon.com and mmoore@barclaydamon.com; Karina Shahine, associate, at kshahine@barclaydamon.com; Danielle Katz, counsel, at dkatz@barclaydamon.com; or another member of the firm’s Corporate Practice Area.

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