On August 15, 2024, during our Membership Meeting monthly call we had a hot topic speaker, Cari Stinebower of Winston & Strawn.  She gave a presentation on the Corporate Transparency Act and the new registration requirements for any company doing business in the USA. She presented to our group and provided the following information below (in summary) and also provided the attached slides for our use and reference. Special thanks to Kathy Rowe of Freehold Capital Management for bringing her to the group. Presentation

On September 30, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a highly anticipated rule (the BOI Reporting Rule) that implements the ultimate beneficial ownership information (BOI) reporting requirements of the Corporate Transparency Act (the CTA).

The CTA, which is part of the Anti-Money Laundering Act of 2020 (the AML Act) and enacted into law as a part of the National Defense Authorization Act for Fiscal Year 2021, establishes BOI reporting requirements for the vast majority of privately held corporations, limited liability companies and other similar entities created in, or registered to do business in, any of the states in the United States (U.S.), including the District of Columbia, Puerto Rico and other U.S. Territories (collectively, Reporting Companies). 

The BOI Reporting Rule became effective on January 1, 2024. Note that on November 29, 2023, FinCEN issued a final rule amending the BOI Reporting Rule to extend the filing deadline for initial BOI reports from 30 calendar days to 90 calendar days for entities created or registered on or after January 1, 2024. Click here to see the final rule. On December 12, 2023, FinCEN published frequently asked questions on the BOI Reporting Rule. Click here to see the FAQs. In addition, FinCEN has published a Small Entity Compliance Guide.  Click here to link to that Guide.