Corporate Transparency Act Update

Congress passed the Anti-Money Laundering Act of 2020 and the National Defense Authorization Act for Fiscal Year 2021, within which was another act: the Corporate Transparency Act (“CTA”).

Generally speaking, the CTA requires, beginning on January 1, 2024, “Reporting Companies” to report to FinCEN certain information about the Reporting Company and about the “Beneficial Owners” of the Reporting Company. Companies created after January 1, 2024, will also need to report information regarding their “Company Applicant”.

Strauss Troy has previously written articles regarding the CTA and its details and you can find them here:

1. Preparing for the Corporate Transparency Act - Part I: What is it?
2. Preparing for the Corporate Transparency Act - Part II: Who is a Beneficial Owner and What Gets Reported?
3. Preparing for the Corporate Transparency Act - Part III: What Gets Reported?

Among the CTA’s many provisions was a requirement that Reporting Companies formed on or after January 1, 2024, file their initial report within 30 days of formation.

However, on November 29, 2023, FinCEN released a final rule providing certain Reporting Companies with 90 days to initially provide the required information, rather than the previously allotted 30 days.The modification, can be viewed in the Federal Register here.

The modification grants new companies that are formed on or after January 1, 2024, but before January 1, 2025, the above mentioned 90 day period to initially provide the necessary information from the date the Reporting Company is formed. It is important to note that this extension does not last forever, and only applies to Reporting Companies formed on or after January 1, 2024, but before January 1, 2025. Thus, in 2025, the initially required 30 day period will be in effect once again.

If you would like more information on the CTA, or would like more information on who is a Beneficial Owner, who is a Company Applicant, and what information must be reported by each and every Reporting Company, please view one of our previous articles linked above.

You can also reach out to Strauss Troy Associate Attorney, Austin Stevenson at RAStevenson@strausstroy.com or 513-768-9745 regarding any questions you may have, or to inquire about Strauss Troy assisting your Reporting Company with CTA obligations.