Upcoming Deadline for Corporate Transparency Act Compliance

As we near the end of 2024, it’s crucial to be aware of an important deadline under the Corporate Transparency Act (CTA). Reporting companies formed before January 1, 2024, must file their initial Beneficial Ownership Information (BOI) report by January 1, 2025. This deadline is fast approaching, and timely compliance is critical to avoid significant penalties, including fines—which can accrue daily—and potential legal action.

Key Points

Who Needs to File: The CTA mandates certain businesses to report information about their beneficial owners and control parties to the Financial Crimes Enforcement Network (FinCEN).

Deadlines:

• Companies formed before January 1, 2024: Initial BOI report due by January 1, 2025.
• Companies formed between January 1, 2024, and December 31, 2024: Initial BOI report due within 90 days of formation.
• Companies formed on or after January 1, 2025: Initial BOI report due within 30 days of formation.
• Updated BOI Reports: Any changes to reported information must be updated by filing a new BOI report within 30 days of the change. This includes updates to beneficial owners, control parties, changes to their information, and changes in exemption status.

Action Steps

1. Determine Filing Requirement: Assess whether your company is required to file a BOI report. This includes determining whether your company falls under one or more of the 23 CTA exemptions, and, if not, understanding who qualifies as a beneficial owner or control party.
2. Collect Information: Gather the necessary information about your beneficial owners and control parties, including names, addresses, and identification numbers.
3. Submit Report: Ensure timely submission of your BOI report to FinCEN to comply with the CTA requirements. FinCEN’s website often undergoes routine maintenance—avoid any last-minute issues by preparing and submitting your BOI report early! 

For more details on filing requirements, beneficial owner definitions, and required information, please refer to FinCEN’s FAQs or contact us for assistance. 

To avoid year-end panic, tune in to Seyfarth’s webinar on December 12, 2024 for a concise overview of key requirements, including which entities must report, what information needs to be disclosed, and best practices for ensuring compliance.