CLIENT ALERT: Last November, we posted a Client Alert related to the impending implementation of the Corporate Transparency Act (the “Act”). You can find that prior Client Alert here. The Act commenced on January 1, 2024, and the reporting obligations under the Act are now in effect. Businesses should understand how they are impacted by these obligations, including recent updates to timing of the required reporting.
Companies covered under the act, including most privately held businesses, must report information about their beneficial owners to the Financial Crimes Enforcement Network (“FinCEN”). Subsequent to our previous Client Alert, FinCEN made changes to the reporting timeframes, extending the filing deadline for companies created in 2024. The updated filing times are as follows:
- For all reporting companies created or registered prior to January 1, 2024, the deadline for filing beneficial ownership information remains January 1, 2025.
- For all reporting companies created or registered on or after January 1, 2024 through December 31, 2024, the deadline for filing will be 90 days after such creation or registration (extended from the initial 30-day period).
- For all reporting companies created or registered on or after January 1, 2025, the deadline for filing will be 30 days after such creation or registration.
Note, also, that reporting companies formed on or after January 1, 2024 must file information regarding “company applicants” along with information on the company’s beneficial owners. “Company applicants” consist of both the person who files the document that creates the reporting company, as well as any other individual who is primarily responsible for controlling or directing the filing of the formation document. Therefore, the Act requires submission of information regarding whomever files the company’s organizational documents, whether that is a founder or individuals at the company’s legal counsel.
Gennari Aronson is available to support clients in efforts to timely and properly file reports with FinCEN under the Act.
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