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  • Elizabeth A. McMorrow

CTA Update: BOI 90-Day Registration

On November 29, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a final rule extending the deadline for certain reporting companies to file their initial beneficial ownership information (BOI) reports under the U.S. Corporate Transparency Act (CTA).

What Is CTA?

The CTA requires certain domestic and foreign entities to report on their beneficial ownership information (BOI). Congress assigned the administration and enforcement of the CTA to FinCEN. FinCEN’s CTA regulations are effective from January 1, 2024.

What Is the Deadline Extension?

Reporting Companies created or registered in 2024 will have 90 calendar days from the date of receiving actual or public notice of their creation or registration becoming effective to file their initial reports. Previously, these companies would have had only 30 days to file their initial report.

Updated FinCEN Guidance Materials

On December 1, 2023, FinCEN announced it has updated its CTA guidance materials, including Questions G.1. and G.2. of the Beneficial Ownership Information Reporting Frequently Asked Questions.

Still Waiting

With the January 1, 2024 CTA start date rapidly approaching, we are still waiting for FinCEN to finalize registration forms, rules regarding portal access, and the portal itself. FinCEN will also revise the existing Customer Due Diligence (CDD) Rule. However, FinCEN has until January 1, 2025 to implement the CDD revision.

In the meantime, some industry groups have submitted letters to FinCEN and/or Congress requesting CTA be postponed for one year to ensure all impacted companies are aware of their CTA obligations.

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