November 29 Rule Change for Beneficial Owner Reporting

As discussed in in our post on November 14, 2023, the Corporate Transparency Act requires many business entities to report information about their beneficial owners in a brand-new government database. This reporting must be done during 2024.

On November 29, 2023, the Financial Crimes Enforcement Network (FinCEN) finalized a new rule that affects entities that are newly-formed during 2024. For entities created on or after January 1, 2024, and before January 1, 2025, filings under the new requirement are due within 90 days of the creation of such an entity, instead of 30 days.

The due date for reports for entities that existed prior to January 1, 2024 remains unchanged, and those reports are due by January 1, 2025.

In addition, for newly-formed entities created on or after January 1, 2025, filings under the new requirement will be due within 30 days of the creation of such an entity. The rule change that allows 90 days to file is only for entities created during 2024.

We will discuss strategies, logistics and other considerations related to this new reporting requirement in our seminars in December and January. If you are not already registered, register here.