What is the Corporate Transparency Act?

In 2021, Congress enacted the Corporate Transparency Act. This law aims to help law enforcement prevent, identify, and combat financial crimes. Under the CTA, most businesses were required to file a Beneficial Ownership Information [BOI] Report with the Financial Crimes Enforcement Network (FinCEN).

As of Mar 2, 2025 The United States Treasury Department will no longer enforce any penalties or fines associated with the BOI reporting rule under the existing regulatory deadlines, however this is subject to change.

Just in 2025 alone, BOI reporting requirements have changed several times. We encourage you to file a BOI Report for your company so that you are not taken by surprise when/if the United States Treasury Department enforces this reporting rule yet again.

Who is Required to File?

Companies required to report Beneficial Ownership Information (BOI) to FinCEN are called reporting companies. At this time, Foreign companies or entities are required to file a BOI Report with FinCEN.

• Foreign reporting companies are entities (including corporations and limited liability companies) formed under the law of a foreign country that have registered to do business in the United States by the filing of a document with a secretary of state or any similar office.

Who is a Beneficial Owner of My Business?

If your business is a reporting company, your next step is to identify its beneficial owners. A beneficial owner is any individual who, directly or indirectly:

• Exercises substantial control over a reporting company;
• OR
• Owns or controls at least 25 percent of the ownership interests of a reporting company.

A reporting company can have multiple beneficial owners.
For example, a reporting company could have one beneficial owner who exercises substantial control over the reporting company, and a few other beneficial owners who own or control at least 25 percent of the ownership interests of the reporting company.

What Information Must be Filed in the BOI Report?

A Reporting Company must report the followings information for each of its beneficial owners:

• Full legal name
• Date of birth
• Current residential address
• Unique Identifying Number from a non-expired state or government issued ID (U.S. passport, State driver's license, etc.)

When Does a Business Need to File a BOI Report?

BOI Reports must be filed by reporting companies within 90 Days of the company's formation. If the reporting company already exists as of January 1, 2024, it must file its initial BOI report by January 1, 2025. We can file your BOI Report for you to ensure you don't miss your deadline.

What Happens if a Business Fails to Comply With the CTA?

FinCEN announced that it “will not issue any fines or penalties or take any other enforcement actions against any companies… until a forthcoming interim final rule becomes effective.” With the ever changing landscape of BOI reporting requirements this year, we encourage you to file a BOI Report for your company so you are prepared when/if the reporting requirements are back in effect.

Is Information Provided to FinCEN Confidential?

Information filed with FinCEN under the Corporate Transparency Act is confidential and is not disclosed to the public. Law enforcement can access this information to investigate potential financial crimes.