THE CORPORATE TRANSPARENCY ACT REPORTING OF BENEFICIAL OWNERSHIP INFORMATION (BOI)
This correspondence is to provide you with notice that the Corporate Transparency Act (CTA) became effective on January 1, 2024 resulting in the Federal requirement for the Reporting of Beneficial Ownership effective January 1, 2024. You may be required to report certain information on your beneficial owners to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). Certain types of corporations, limited liability companies, and other similar entities created in or registered to do business in the United States must report information about their beneficial owners. The persons who ultimately own or control the company, must be reported to FinCEN. If you are a company required to report, the initial beneficial ownership information reporting is based on the date your company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.
FinCEN does not impose a fee for the filing of the Beneficial Ownership Information report. There are, however, civil ($500/day) and criminal (2 years in jail) penalties for failing to file. If you have questions regarding this new Reporting Rule, please contact our office.
KEY FILING DATES
Reporting companies created or registered before January 1, 2024, reports due by January 1, 2025.
Reporting companies created or registered on or after January 1, 2024, and before January 1, 2025, have 90 calendar days after receiving actual or public notice that their company’s creation or registration is effective to file their initial BOI reports.
Reporting companies created or registered on or after January 1, 2025, will have 30 calendar days from receipt of actual or public notice that their creation or registration is effective to file their initial BOI reports
That is, companies formed this year have less time to file than companies formed last year. A company formed on December 31, 2023, has until January 1, 2025 to file, while a company formed on January 1, 2024 has until April 1, 2024 to file. There will be even less time, 30 days, for companies formed next year.
ONGOING REPORTING REQUIREMENTS
When there is a change to previously reported information about the reporting company itself or its beneficial owners, updated reports must be submitted within 30 calendar days after a change occurs.
