On November 30, 2023, the Financial Crimes Enforcement Network of the Department of the Treasury (FinCEN) proposed a final rule (the “Amended Final Rule”) that amends FinCEN’s previous final rule on reporting beneficial ownership information (BOI) under the Corporate Transparency Act. The Amended Final Rule extends the filing deadline for reporting companies formed or registered in 2024 to 90 calendar days, instead of 30 calendar days, from the date of receiving actual or public notice of their creation or registration becoming effective.

Reporting companies formed prior to January 1, 2024 will still have until January 1, 2025 to file their initial BOI reports with FinCEN, and reporting companies formed on or after January 1, 2025 will continue to have 30 calendar days to file their initial BOI reports with FinCEN. For a more detailed discussion of the Corporate Transparency Act and its reporting requirements, please see our previous client alert, Corporate Transparency Act and its Reporting Requirements.

Please contact Moses Singer if you have any questions or concerns regarding the Corporate Transparency Act.  Please note that we will not be reviewing our files for, or providing advice on, Corporate Transparency Act compliance for existing entities (those formed prior to January 1, 2024) or for entities formed by third parties after January 1, 2024, unless specifically requested to do so.  Moses Singer looks forward to assisting its clients with the filing requirements and compliance obligations of the Corporate Transparency Act as so requested.