As previously reported by Seyfarth, the Corporate Transparency Act ("CTA") will become effective January 1, 2024. While there are exceptions, the CTA applies to most entities with less than 20 employees. Specifically, these entities must file a disclosure as to beneficial ownership and certain other matters with the Financial Crimes Enforcement Network ("FinCEN"). Filing for those entities formed on or after January 2024 is required within 30 days of formation. Entities formed before January 1, 2024, have until January 1, 2025, to file. A link to our prior discussion of the statute can be found here.
Following up on our earlier publication, on September 18, 2023, FinCEN issued Guidelines and FAQs regarding the upcoming changes required by the CTA. There is little new in these materials. However, FinCEN advises that (i) it will not accept any disclosure filings before January 2024, and (ii) the disclosure form which will need to be filed with FinCEN is still being developed. When ready, the form will be available on the FinCEN website.
Links to the materials released by FinCEN on September 18 can be viewed through the Small Entity Compliance Guide and FAQ document.
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