The Legal Brief
Update: Understanding the Corporate Transparency Act, Part II
December 1, 2023
We recently provided an overview of the Corporate Transparency Act or the “CTA,” which will go into effect on January 1, 2024 and require most businesses to report information about themselves and their owners to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). That article is linked here. The article notes that a proposed amendment to the CTA would extend the reporting deadline for new entities formed between January 1, 2024 and January 1, 2025 from 30 days post-formation to 90 days. On November 29, 2023, FinCEN announced the issuance of a final rule officially extending that deadline. Companies formed between January 1, 2024 and January 1, 2025 will be required to report their information to FinCEN within 90 days of the date of formation. Companies formed after January 1, 2025 will be required to report their information no later than 30 days after the date of formation. Currently existing entities and those formed before January 1, 2024 will continue to have until January 1, 2025 to report their information.
In the November 29, 2023 announcement, FinCen Director Andrea Gacki said, “this deadline extension will have significant benefits and will provide valuable extra time for company applicants and for reporting companies created or registered in 2024 to understand this new regulatory obligation and obtain the required information to file their BOI reports.” If you or your business need help understanding or meeting the requirements of the CTA, please reach out to a member of our team here at Jackson Kelly.