Company Law Update -- Federal Rules for Reporting Beneficial Ownership of Entities Reinstated
Background
We previously reported that on January 1, 2024, new federal rules promulgated pursuant to the 2021 Corporate Transparency Act (“CTA”) became effective, governing the disclosure of beneficial ownership information (“BOI”) for a Reporting Company with new rules implemented by the U.S. Treasury Department's Financial Crimes Enforcement Center unit (FinCEN).
We later reported that at the direction of the entire Fifth Circuit Court of Appeals, the Clerk of the Court entered an order reinstating a preliminary injunction staying enforcement of the CTA pending appeal, noting that an expedited appeal had been ordered.
Important new development
The stay has now been lifted. Existing companies are now required to file with FinCen by no later than March 21, 2025. Companies formed after February 18, 2025 must file within 30 days of formation.
Where can I find the Initial Report Form?
The form of the report is now available here. The form is available in PDF format, requiring Adobe Reader 8 application software for completion offline, and then uploaded for online filing. In the alternative, this form may be completed and submitted online, without the need for an additional software tool.
Please contact: Simon Gerson (212) 790-9206 or Robert J. Giordanella (212) 790-9234 for assistance.
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Counsel
Email | 212.790.9206
Simon has more than 30 years of experience counseling and attending to the varied commercial and corporate needs of established privately-held businesses and their principals.
Partner
Email | 212.790.9234
Bob concentrates on succession planning and estate and trust administration.
He also handles significant commercial transactions, including the purchase and sale of publishing and other media related companies and businesses involved in the sale, distribution or manufacture of various consumer products.