November 13, 2024 Corporate Transparency Act

Many companies are required to report information to Financial Crimes Enforcement Network (FinCEN) about the individuals who ultimately own or control them. FinCEN began accepting reports on January 1, 2024. FinCEN launched the Beneficial Ownership Interest (BOI) E-Filing website for reporting beneficial ownership information on January 1, 2024. Please see https://urldefense.com/v3/\_https://linkprotect.cudasvc.com/url?a=https\*3a\*2f\*2fwww.fincen.gov\*2fboi&c=E,1,WrHLE6YcoKq9Y49MPHxmyItOzb7ga01tvjPvsw4yyZd06we1z23dmks5e3lFH3BeJNRTPrklIdXAtrxiUC8FxwYsSynBXSHTDpuh5ZDIqaFVCYmxkZHv-QtEIcU,&typo=1&ancr\_add=1\_;JSUlJQ!!Hj18uoVe\_Lnx!veHsjDEwmGswhnhauOauMaV0ae9IHWsCS6s0\_tVi28zUv8MvAWyuwsrSHi8Zu1jxfa20MsI27pOkDTnOoSJagFA$https://www.fincen.gov/boi to prepare to file and file a BOI report for a reporting company or to determine if you qualify for an exemption. There are frequently asked questions available along with the responses by FinCEN.

The deadlines are disclosed on the FinCEN BOI website. Here are a few of the deadlines:

  • A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025, to file its initial BOI report.

  • A reporting company created or registered in 2024 will have ninety (90) calendar days to file after receiving actual or public notice that its creation or registration is effective.

  • A reporting company created or registered on or after January 1, 2025, will have thirty (30) calendar days to file after receiving actual or public notice that its creation or registration is effective.

​The Corporate Transparency Act provides that a person who willfully violates the BOI reporting requirements may be subject to civil penalties of up to $500 (adjusted annually for inflation) for each day that the violation continues. As of the time of the publication of that FAQ, this amount is $591. Further, a person who willfully violates the BOI reporting requirements may also be subject to criminal penalties of up to two (2) years imprisonment and a fine of up to $10,000.

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