November 14, 2024
To: Clients and Friends
From: Daniel S. Engle
Subject: Reminder of Federal Beneficial Ownership Information Reporting Requirements for Certain Corporate Entities
Subject As a reminder to clients and friends, federal law (the Corporate Transparency Act) imposed a requirement for certain corporate entities to file beneficial ownership information with the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). This includes many small corporations and limited liability companies as well as other entities created by the filing of a document with a secretary of state (or similar official) under the law of a State or Native American tribe. Twenty-three specific types of entities, including banks, credit unions and “large operating companies” are exempt from the reporting requirements. For entities subject to the reporting requirements that were created before January 1, 2024, the deadline to file beneficial ownership information will be January 1, 2025. For entities created during 2024, the deadline is 90 days after formation. For entities created on or after January 1, 2025, the deadline will be 30 days after formation.
Clients and friends are advised to check with their accountants to confirm that any necessary responsibilities will be addressed. FinCEN has more information about the reporting rule on their website: https://www.fincen.gov/boi .
This Memorandum is provided as general information in regard to the subject matter covered, but no representations or warranty of the accuracy or reliability of the content of this information are made or implied. Opinions expressed in this memorandum are those of the author alone. In publishing this information, neither the author nor the law firm of Black, Mann & Graham L.L.P. is engaged in rendering legal services. While this information concerns legal and regulatory matters, it is not legal advice and its use creates no attorney-client relationship or any other basis for reliance on the information. Readers should not place reliance on this information alone but should seek independent legal advice regarding the law applicable to matters of interest or concern to them. The law firm of Black, Mann & Graham L.L.P. expressly disclaims any obligation to keep the content of this information current or free of errors.
Full Memorandum
