Beginning January 1, 2024, new regulations by the Financial Crimes Enforcement Network (FinCEN) under the Corporate Transparency Act (CTA) require many entities to report information regarding their “beneficial owners” and “company applicants.” This new requirement is anticipated to affect approximately 32 million existing entities and an estimated 5 million new entities annually moving forward. 

This reporting requirement applies with respect to entities (i.e., corporations, limited liability companies, and limited partnerships) that fall under the CTA’s definition of “reporting company” and do not otherwise qualify for one of the CTA’s twenty-three exemptions. For additional information regarding reporting companies and available exemptions, please see our FAQ publication. 

The CTA imposes various deadlines for reporting companies to file their initial reports, depending on when the reporting company was formed. Notably:

1. Reporting companies formed prior to January 1, 2024:
   • Initial report must be filed by January 1, 2025.
2. Reporting companies formed in 2024:
   • Initial report must be filed within 90 days of formation.
3. Reporting companies formed on or after January 1, 2025:
   • Initial report must be filed within 30 days of formation.

As we approach the end of the year, reporting companies that were formed prior to January 1, 2024 and haven’t already filed their initial reports should begin gathering the information necessary to complete and file their initial reports by the January 1, 2025 deadline.  

To learn more, explore our suite of resources prepared by the firm to address frequently asked questions and offer guidance on complying with the CTA. For additional support we invite you to reach out to a member of the Koley Jessen Corporate Transparency Task Force.

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