Update as of 10/18/2023

Corporate Transparency Act Update

The Corporate Transparency Act’s (CTA) reporting requirements, effective January 1, 2024, will impact most companies across the country. However, many companies remain unaware of their new reporting obligations.

Key Questions for Companies

As the effective date approaches, companies should consider several key questions.

  1.  Am I exempt from filing a beneficial ownership report (“BOI Report”) with the Financial Crimes Enforcement Network (“FinCEN”)
  2.  Who are my beneficial owners?
  3.  Who are my company applicants?

Our Plan

We will be offering BOI Report filings as a product to our clients and are building a secure system that clients will use to upload their information for the filings. We will inform clients of our pricing for the filings in the fourth quarter of this year.

Legislative Trends

Two pieces of legislation have been introduced in Congress that, if passed, would impact the implementation of the CTA: the Protecting Small Business Information Act of 2023 and the Protect Small Business and Prevent Illicit Financial Activity Act.

Additionally, there is a growing movement among states to require companies to report beneficial ownership information in ways similar to the CTA. The New York legislature has passed the LLC Transparency Act which will require LLCs to report beneficial ownership information to the Department of State. Similar legislation has been introduced in California and Massachusetts.

We will continue to keep you up to date on the CTA and the legislative trends. For more information, visit our CTA resource page here: https://www.capitolservices.com/cta/